960911.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
ATTORNEY FOR THE COMMISSION STAFF
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION
IN THE MATTER OF THE INVESTIGATION)
OF CAPITOL WATER CORPORATION AND ) CASE  NO.  CAP-W-96-1
ITS ABILITY TO PROVIDE ADEQUATE)
SERVICE AND WATER QUALITY.)    
)FIRST PRODUCTION
)REQUEST OF THE
)COMMISSION STAFF
)TO CAPITOL WATER
_____________________________________________)CORPORATION
The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests Capitol Water Corporation provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before TUESDAY, OCTOBER 1, 1996.
This production request is to be considered as continuing, and Capitol Water Corporation (Capitol; Company) is requested to provide by way of supplementary responses, additional documents that you or any person acting on your behalf may later obtain that will augment the documents produced.
Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
Request No. 1:  Please give a brief history of the iron and manganese problem in Capitol's water supply.  Please provide a copy of all correspondence with Idaho Department of Health and Welfare (DEQ) regarding same.
Request No. 2:  What has the Company done in the past to alleviate this problem?
Request No. 3:  What are the alternatives the Company is considering to solve the iron and manganese problem?  Please provide a cost estimate for each.
Request No. 4:  How soon can flowmeters be installed at Well No. 6 and Well No. 4?
Request No. 5:  How soon can a sequestering injection device be installed which can match the variable flow characteristics of the Well No. 6 pump.?
Request No. 6:  Please provide test data showing the iron and manganese content in water produced by Well No. 6 and Well No. 4.
Request No. 7:  If shutting down Well No. 6 is a temporary solution, when will seasonal  decreased system demand allow the shutdown of the well?
Request No. 8:  Does the Company have any plans to shut down Well No. 4?
Request No. 9:  Please provide a complete list of customer inquires and complaints received by the Company since Order No. 26247 was issued in Case No. CAP-W-95-1.  Please provide copies of all Company records regarding same.
Request No. 10:  Previously Well No. 3 was de-rated from 1500 gpm to 850 gpm and Well No. 2 was de-rated from 500 gpm to 250 gpm.  What is the current status of the two wells?  What is the current capacity of all six wells?
Request No. 11:  Please indicate the Company's conservation efforts for calendar year 1996.  Provide copies of materials provided to customers, indicating the method and timing of distribution.   
DATED  at Boise, Idaho, this              day of September 1996.
______________________________________
Scott Woodbury
Deputy Attorney General
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