20230316Staff to ATW 1-21.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION i 6
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ATOMIC WATER )WORK'S APPLICATION FOR A )CASE NO.ATW-W-23-01
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ATOMIC WATER WORKS
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Atomic Water Works ("Company")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,APRIL 6,2023.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO ATOMIC WATER WORKS 1 MARCH 16,2023
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.
REQUESTNO.1:Please provide a copy of the Company's QuickBooks file.Please
ensure that this file has data from January 1,2020,throughFebruary 28,2023.Please also note
which edition of QuickBooks is currentlyused,and provide sufficient credentials,such as
username and password,to access the file.An external accountant login for the QuickBooks file
should be sufficient.
REQUESTNO.2:Please provide a printed copy of PDF file of the Company's income
statement and balance sheet from QuickBooks used by the Company for the Calendar Years
Ended ("CYE")2020,2021,and 2022.
REQUESTNO.3:Please provide all copies of customer billings from August 2022
through February 2023.
REQUESTNO.4:Please provide copies of all power bills from January 2020 through
February 2023.
REQUESTNO.5:Funds were received from Bingham County for customers who had
credit on account.Please provide a list of customers and amounts,and how those funds from
Bingham County were entered into QuickBooks.Please include a current (February 2023)list of
customers who have a credit on their account.
REQUESTNO.6:Please provide all documentation showing the transfer of the water
system assets from the former city to Atomic Water Works,LLC.
REQUESTNO.7:Please provide all documentation and analysis used by the Company
in determining the value of the former city water system's assets compared to the value of the
assets used to determine the purchase price.
FIRST PRODUCTION REQUEST
TO ATOMIC WATER WORKS 2 MARCH 16,2023
REQUESTNO.8:Please provide all documentation used by the Company in
performing its due diligence for the purchase of the former city water system's assets such as
evaluations of the condition of pumps,distribution lines,buildings,etc.
REQUESTNO.9:Please describe the applicant(s)prior experience conducting the
business and operating a public potable drinking water system.
REQUESTNO.10:Please provide the legal description for the service territory that is
being requested in the Application for a Certificate of Public Convenience and Necessity
("CPCN").
REQUESTNO.11:Please provide a thorough and complete description of the system
being acquired.This should include any known deficiencies that need to be addressed to
maintain system integrityand to support growth,as well as any changes/investments that the
Company plans to implement to address deficiencies relative to items included below.Please
include the costs and benefits for any future investments or potential increases in expense:
a.Processes and methods.This should include processes involved in the delivery of
water and business processes (i.e.,billing,maintenance,customer support,etc.);
b.Manpower/staffing,including the amount of labor and the level of
expertise/experience;
c.Equipment/infrastructure/software both direct (i.e.,pipes,tanks,and pumps)and
indirect (maintenance equipment,computers,etc.);
d.Policies and standards (i.e.,service level,maintenance turnaround time,etc.);and
e.Materials (productive material used for water quality,spare parts inventory,etc.).
REQUESTNO.12:Please provide an up-to-date geo-spatial system map showing the
location and elevation of major equipment including wells,distribution piping,storage tanks,
booster pumps,shut-off valves,meters,fire hydrants,and water treatment equipment.Please
also include the followinginformation:
a.The make,model,and rating of each well pump;
b.The make,model,and rating of each well pump motor;
FIRST PRODUCTION REQUEST
TO ATOMIC WATER WORKS 3 MARCH 16,2023
c.The make,model,capacity,and limit switch settings of each pressurized storage
tank;
d.The make,model,capacity,and limit switch settings of each unpressurized
storage tank/reservoir;
e.The make,model,and rating of each booster pump and motor;
f.The make,model,and capacity of all water treatment equipment;
g.The year,make,model,and capacity for backup generation supporting the well
pumps.Indicate if the generation has an Automatic Transfer Switch ("ATS")or if
it must be manuallystarted;and
h.The distribution piping line size and materials specified in the installation.
NOTE:Please provide this map in an electronic format which can be enlarged to identify
all aspects of the system.
REQUESTNO.13:If the system includes fire protection,please provide the following:
a.The name and contact information for the fire authoritywho prescribes
requirement for the system;and
b.Fire flow and storage requirements prescribed by the fire authority.
REQUESTNO.14:Please provide the specified material requirements and construction
details used in the installation of the distribution system piping.
REQUESTNO.15:Please provide information related to the capacity and sizing of the
system and the ability of the system to meet historical and future system peak demand.
Information would include not only capacity/constraints of/in the system,but also average
consumption and consumption at peak periods.
REQUESTNO.16:Please provide the most recent Idaho Division of Environmental
Quality Sanitary Survey.
REQUESTNO.17:For each water right used by the system,please provide the Idaho
Department of Water Resources Water ("IDWR")Right Numbers (basin and sequence number).
FIRST PRODUCTION REQUEST
TO ATOMIC WATER WORKS 4 MARCH 16,2023
REQUESTNO.18:For each well used by the water system,please provide the
following:
a.The Idaho Department of Water Resources Well Tag Number (D-Tag Number)
currentlyon-file with IDWR;
b.Location (Township,Range,Section,and Tract);and
c.The well log.
REQUESTNO.19:Please provide an estimate of total unaccounted water losses due to
leaks,wasted water,etc.by month over the past 5-years.Please explain how these losses are
estimated.
REQUESTNO.20:Please provide the monthlymetered amount of water produced by
each well over the past 5-years?
REQUESTNO.21:Please indicate whether any private water,municipal water,or
Commission regulated water utilities overlap the customer service territoryof the Atomic Water
Works water system.If so,please explain any effect to the requested Certificate of Public
Convenienceand Necessity ("CPCN").
DATED at Boise,Idaho,this )day of March 2023.
Claire Sharp
Deputy AttorneyGeneral
i:umisc:prodreq/atww23.lcstg prod req l
FIRST PRODUCTION REQUEST
TO ATOMIC WATER WORKS 5 MARCH 16,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF MARCH 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ATOMIC WATER WORKS,IN CASE NO.ATW-W-23-01,
BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
VICKIE O'HARO
OWNER/MANAGER
ATOMIC WATER WORKS
1772 N 2650 W
ATOMIC CITY ID 83215
E-MAIL:[e-mail]
SECRETÀ¾Y
CERTIFICATE OF SERVICE