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Home My WebLink About20250210Staff 164-171 to VEO.pdf RECEIVED Monday, February 10, 2025 3:20:35 PM IDAHO PUBLIC UTILITIES COMMISSION 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 VEOLIA WATER ) IDAHO, INC.'S APPLICATION TO ) CASE NO.VEO-W-24-01 INCREASE ITS RATES AND CHARGES FOR ) WATER SERVICE IN THE STATE OF ) IDAHO ) REDACTED NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO VEOLIA WATER IDAHO, INC. Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Chris Burdin, Deputy Attorney General, requests that Veolia Water Idaho, Inc. ("Company") provide the following documents and information as soon as possible, but no later than MONDAY, FEBRUARY 24, 2025.1 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. REDACTED NINTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 1 FEBRUARY 10, 2025 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. 164: In reference to response to Production Request No. 105 for the Hillcrest Tank Replacement project(ID C2IE510_060), the actual cost for"Contractor, Material, Tools, Equipment, Trans." is-, while the contractor cost is-- Please reconcile the difference. Please also provide supporting documents including but not limited to Procurement Review Forms ("PRFs") and invoices, as evidence. REQUEST NO. 165: In reference to response to Production Request No. 106 for the 2023 Pump Equipment project (ID C23C101_060),please respond the following: a. Please provide any contractors' cost information for the actual cost of the "Contractor, misc"item in the Overland Well Piping Rehab project (C23C101_060_016), Kirkwood Well Piping Rehab project(C23C101_060_017), and JR Flats Well Pump project (C23C101_060_034) with supporting documents including but not limited to PRFs and invoices as evidence; and b. Please explain the_ budget overrun excluding AFUDC and local/corporate overheads. REQUEST NO. 166: In reference to response to Production Request No. 107 for the Pump Equipment project(ID C22C 10 1_060), the actual cost for"Contractors, Consultants" in the EWC Well 4 Genset Install project(ID C22C101_060_006) is-, while total contractor costs is-. Please reconcile the- difference and provide supporting documents including but not limited to PRFs and invoices, as evidence. REQUEST NO. 167: In reference to response to Production Request No. 108 for the CL2 Generator Replacement project (ID C2213507_060),please reconcile the difference between the actual cost of"Supplies" and contractor cost_ in the Bali Hai 300 PPD REDACTED NINTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 2 FEBRUARY 10, 2025 project(C2213507_060_003). Please also provide supporting documents including but not limited to PRFs and invoices, as evidence. REQUEST NO. 168: In reference to response to Production Request No. 110 for the Bench WQ Master Plan project(ID C21KO08_060), the actual cost for"Contractors and Other Direct Costs" is_, while the contractor cost, including change orders, is_- Please reconcile the difference. Please also provide supporting documents including but not limited to PRFs and invoices, as evidence. REQUEST NO. 169: In reference to response to Production Request No. 112 for the Planning Secure site c project(ID C21A102_060), the actual cost for"Contractors and Testing" is-, while the contractor cost is_. Please reconcile the- difference and provide supporting documents including but not limited to PRFs and invoices, as evidence. REQUEST NO. 170: In reference to response to Production Request No. 114 for the Upgrade PRV Stations project(ID C23C517_060), the actual cost for"Contractors/engineering consultants" is-� while the contractor cost is_. Please reconcile the difference and provide supporting documents including but not limited to PRFs and invoices, as evidence. REQUEST NO. 171: Regarding the Brown water issue in the Boise Bench area,please respond to the following: a. Please explain whether the magnesium ion ("Mg2+") concentration in treated water by media filtration in the Taggart Wells meets EPA drinking water regulations; b. Please explain whether the Mg2+ concentrations are monitored before and after the treatment facility and at the consumers' connection points. If so, please explain how often the Company performs the monitoring; c. Please explain how often the cleaning of water mains is done; and d. Please explain whether new lining work inside pipelines is done after the water main cleaning. If not,please explain the reason. REDACTED NINTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 3 FEBRUARY 10, 2025 DATED at Boise, Idaho, this 10`I' day of February 2025. Chris Burdin Deputy Attorney General I:%Utility\UMISC%PRDREQ\VEO-W-24-01 PR#9(Redacted)docx REDACTED NINTH PRODUCTION REQUEST TO VEOLIA WATER IDAHO, INC. 4 FEBRUARY 10, 2025 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS DAY OF FEBRUARY 2025, SERVED THE FOREGOING REDACTED NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO VEOLIA WATER IDAHO, INC. , IN CASE NO. VEO-W-24-01, BY E-MAILING A COPY THEREOF,TO THE FOLLOWING: PRESTON N CARTER DAVID NJUGUNA MEGAN D. GOODIN DIRECTOR —REGULATORY BUSINESS MEGANN E. MEIER VEOLIA WATER M&S (PARAMUS), INC. GIVENS PURSLEY LLP 461 FROM ROAD, SUITE 400 PO BOX 2720 PARAMUS, NJ 07052 BOISE ID 83701-2720 E-MAIL: david.niuguna a,veolia.com E-MAIL: prestoncarter u,givenspursley.com morgangoodin(u_givenspursley.com mem u,givenspursley.com stephaniew c-givenspursley.com AUSTIN RUESCHHOFF MARY R. GRANT THORVALD A NELSON DEPUTY CITY ATTORNEY AUSTIN W JENSEN BOISE CITY ATTORNEY'S OFFICE KRISTINE A.K. ROACH 150 N. CAPITOL BLVD. HOLLAND & HART LLP PO BOX 500 555 17TH ST STE 3200 BOISE, ID 83701-0500 DENVER CO 80202 E-MAIL: mrgrant�cityofboise.org E-MAIL: darueschhof'f(u hollandhart.com boisecityattorneyacityofboise.org tnelson�hol landhart.com awiensen[r.�hol landhart.com karoach r�hollandhart.com aclee(c-�hollandhart.com STEVEN HUBBLE CLIMATE ACTION SENIOR MANGER ROBIN LEE-BEUSAN WATER RESOURCES PROGRAM COORDINATOR E-MAIL: shubble(a cityofboise.org rleebeusangcityof boise.orb PATRICIA JORD N, SECRETARY CERTIFICATE OF SERVICE