20250224VEO to Staff 171.pdf

RECEIVED
Monday, February 24, 2025
IDAHO PUBLIC
Preston N. Carter, ISB No. 8462 UTILITIES COMMISSION
Morgan D. Goodin, ISB No. 11184
Megann E. Meier, ISB No. 11948
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
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Attorneys for Veolia Water Idaho, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. VEO-W-24-01
OF VEOLIA WATER IDAHO, INC. FOR A )
GENERAL RATE CASE ) VEOLIA WATER IDAHO,INC.'S
RESPONSE TO THE NINTH PRODUCTION
REQUEST OF COMMISSION STAFF
)
)
Veolia Water Idaho, Inc. ("Veolia" or"Company")provides the following in response to
the Ninth Production Request of the Commission Staff dated February 10, 2025. Responsive
documents are available for download using the link provided in the accompanying email.
Confidential responses and documents are subject to the protective agreement in this case, and
are available for download using a password-protected link that will be provided separately by
email. The password will be provided in a third email.
Dated: February 24, 2025.
VEOLIA WATER IDAHO,INC.
Preston N. Carter
Attorney for Veolia Water Idaho, Inc.
RESPONSE TO STAFF's NINTH PRODUCTION REQUEST PAGE I OF 2

CERTIFICATE OF SERVICE
I certify that on February 24, 2025, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:
Commission Staff Via Electronic Mail
Monica Barrios-Sanchez, Commission Secretary [e-mail]
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Chris Burdin [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Micron Technology, Inc.
Austin Rueschhoff [e-mail]
Thorvald A. Nelson [e-mail]
Austin W. Jensen [e-mail]
Kristine A.K. Roach [e-mail]
Holland& Hart, LLP [e-mail]
555 17t' Street, Suite 3200
Denver, CO 80202
City of Boise
Mary R. Grant [e-mail]
Deputy City Attorney [e-mail]
Boise City Attorney's Office
150 N. Capitol Blvd.
Boise, ID 83701
Steven Hubble [e-mail]
Climate Action Senior Manager [e-mail]
Robin Lee-Beusan
Water Resources Program Coordinator
/
Preston N. Carter
RESPONSE TO STAFF'S NINTH PRODUCTION REQUEST PAGE 2 OF 2

VEOLIA WATER IDAHO,INC.
CASE VEO-W-24-01
NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
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
Please explain whether new lining work inside pipelines is done after the water main cleaning. If
not,please explain the reason.
RESPONSE NO. 171:
a. Drinking water utilities are not regulated by the EPA for magnesium"Mg2+". I believe
the question is related to manganese(Mn)which can cause discoloration of water. The
EPA established a Secondary Maximum Contaminant Level (SMCL) of 0.05 mg/L for
manganese. There is also a health advisory limit for manganese of 0.30 mg/L. The
SCML is based on aesthetic concerns and is not an enforceable standard. However,the
Taggart wells water are below the SCML for manganese, see table below for Taggart
#1 & 2 results.
TAGGART #1 & 2
Taggart#1 Raw Taggart#2 Raw Taggart#1&2 Treated
m P m Pm
Date Fe Mn Fe Mn Fe Mn
12/5/2022 <0.05 0.033 <0.05 0.031 <0.05 <0.005
4/26/2023 <0.05 0.035 0.21 0.05 <0.05 <0.005
6/7/2024 <0.05 0.037 0.06 1 0.036 <0.05 <0.005
b. Monitoring of the Taggart treatment facility occurs before and after treatment to
VEO-W-24-01
IPUC DR 171
Page 1 of 2

determine the effectiveness of the treatment. Monitoring at customers' connection
points does not occur. This would require pulling the metered connections apart to test
the water. Sampling stations were installed in distribution pipelines to capture system
chemistry during the Bench WQ Master Plan that was provided in DR No. 110. The
monitoring concluded with the Bench WQ Master Plan study. We monitor this
annually in accordance with Idaho Department of Environmental Quality
Requirements.
c. Water mains are cleaned through unidirectional flushing twice a year. The water mains
are not lined as this would require taking the mainline apart and many of the mains
aren't large enough to line. Instead, Veolia has been replacing pipelines with new in
the bench area.
VEO-W-24-01
IPUC DR 171
Page 2 of 2

GIVENS PURSLEYLLP
Attorneys and Counselors at Law
601 W.Bannock Street
PO Box 2720
Boise,ID 83701
Main:208-388-1200
www.givenspursley.com
Preston N.Carter
Direct:208-388-1222
[e-mail]
February 24, 2025
Via Email ([e-mail])
Monica Barrios-Sanchez
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
Re: Veolia Water Idaho, Inc. Case No. VEO-W-24-01
Dear Ms. Barrios-Sanchez:
On behalf of Veolia Water Idaho, Inc. ("Veolia"), enclosed for filing are the confidential
responses to the Ninth Production Request of Commission Staff.
Pursuant to Idaho PUC Rules of Procedure IDAPA31.01.01.067, 31.01.01.233, and
31.02.01.005.07 and the protective order signed by the parties in this proceeding, the enclosed
information is confidential,proprietary and trade secret information of Veolia and is protected by
law from public inspection, examination or copying, pursuant to Idaho Code Sections 74-106,
107, and 48-801 et seq. Veolia therefore requests that the enclosed information be protected from
inspection, examination or copying by any person other than the Commissioners and PUC Staff.
The confidential information covered by this letter is available for download from sharefile link
provided in the accompanying email.
Please let me know if you have questions or would like to discuss
Sincerely,
Preston N. Carter
cc: David Njuguna,Veolia North America
Counsel of Record