20090324Staff 1-38 to EAG.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
E
2089 MAR 24 PM 3: 28
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF EAGLE WATER )
COMPANY'S APPLICATION FOR )
AUTHORITY TO IMPLEMENT A CUSTOMER )SURCHARGE. )
)
)
)
)
CASE NO. EAG-W-09-1
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
EAGLE WATER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Donald L. Howell, II, Deputy Attorney General, requests that Eagle Water Company (Eagle
Water; Company) provide the following documents and information as soon as possible, but no
later than TUESDAY, APRIL 14,2009.
The Company is reminded that responses pursuant to Commission Rules of Procedure must
include the name and phone number of the person preparng the document, and the name, location
and phone number of the record holder. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and Eagle Water is requested to
provide, by way of supplementary responses, additional documents that it or any person acting on
its behalf may later obtain that wil augment the documents produced.
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 1 MARCH 24, 2009
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.
Well No. 7
Request No.1: Please submit a cost breakdown for the development of Well NO.7 into
the following categories: a) land purchase (and identify the seller); b) well drillng/development; c)
pump and motor d) electrical controls; e) variable frequency drive; t) appurtenances; g) pump
facility building; h) back-up generator; i) mainline tie-in; and j) engineering costs. Please provide
the invoices and other documents supporting these costs.
Request No.2: Please provide the depth and size (diameter) of the well.
Request No.3: Please provide the design capacity (gpm) of pump and size of motor (hp).
Request No.4: Please provide the size of back-up generator (kW).
Request No.5: Please provide the as-built plans for the completed Well NO.7 (well,
pumping plant, back-up generator and mainline tie-in).
Request No.6: Please provide an explanation and documentation (competitive bid
documents, selection process, work contracts, etc.) showing that cost control efforts have been
applied in paying for any of the work elements for Well NO.7 (i.e., well development, installation
of pumps and motors, back-up generators, etc.), to be sure that the project is built as economically
as possible.
Request No.7: Please provide a copy of the well completion report and ground water
right/permit associated with Well No.7, including the well driler's log and test results.
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 2 MARCH 24, 2009
Floating Feather PRSV
Request No.8: Please provide the as-built plans for the pressure regulating/sustaining
valve project.
Request No.9: Please submit invoices supporting the payments made for this project.
Request No. 10: Please provide an explanation and documentation (competitive bid
documents, selection process, work contracts, etc.) showing that cost control efforts have been
applied in contracting and/or paying for any of the work elements for the PRSV project.
Tie-in to Eagle City Water System
Request No. 11: Please provide the as-built plans for the tie-in to Eagle City Water
System project.
Request No. 12: Please submit invoices supporting the payments made for the completion
of the Tie-in project including materials, installation and engineering (MTC, Inc. and City of
Eagle).
Request No. 13: Please explain the engineering cost paid to the City of Eagle ($9,147,
Application, p. 3).
Request No. 14: Please provide an explanation and documentation (competitive bid
documents, selection process, work contracts, etc.) showing that cost control efforts have been
applied in contracting and/or paying for any of the work elements for the Tie-in to Eagle City
Water System.
Request No. 15: The Application indicates that the total cost incured in the Tie-in to the
City of Eagle Water System was $22,347. However, the previous cost estimate for this project as
presented in the Final Engineering Report (page 6) was $ 1 5 1 ,250. Is there stil additional work to
be done on this project? Please cite the reasons and factors why there is a huge reduction of costs
between the actual cost and original cost estimate.
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 3 MARCH 24, 2009
Rebuilding Well No.4
Request No. 16: The Final Engineering Report indicates that Well NO.4 was rebuilt to
provide additional water source. The Company's Notice to Customers also indicates that this is a
mandatory action required by IDEQ. Please provide an explanation/documentation (i.e. Consent
Order, IDEQ letters, etc.) that this project was a mandated action that needs to be completed.
Request No. 17: Staff notes that the work done in rebuilding Well NO.4 includes
increasing the motor size and adding one pump bowL. Please provide the rated capacity of the
original and new pump (gpm) and motor (hp) in Well NO.4.
Request No. 18: Please submit invoices supporting the payments made for various items
related to rebuilding Well NO.4 including motor, pump, electrical, and other costs ($58,575) and
engineering ($ 1,200).
Request No. 19: Please provide an explanation/documentation (competitive bid
documents, selection process, work contracts, etc.) showing that cost control efforts have been
applied in contracting and/or paying for any of the work elements for rebuilding Well NO.4.
Booster Pump Rehabiltation for Well No.2
Request No. 20: The Company's Notice to Customer (Exhibit H) indicates that
rehabiltating the booster pump of Well NO.2 is a mandatory action required by IDEQ. Please
provide an explanation/documentation (i.e. Consent Order, IDEQ letters, etc.) stating that this
project was a mandated action that needs to be completed.
Request No. 21: Please submit invoices supporting the payments made for various items
related to the rehabiltation of the booster pump for Well NO.2 including the lOO-hp pump and
recorder ($94,000), generator set ($75,000) and engineering ($5,700).
Request No. 22: Please provide a cost breakdown of the 100-hp pump and the recorder.
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 4 MARCH 24, 2009
Request No. 23: Please provide the size (kW) of the generator set.
Request No. 24: Please provide the as-built plans for the Well NO.2 Booster Pump
Rehabiltation project.
Request No. 25: The previous cost estimate for the Booster Pump Rehabiltation project
as presented in the 2007 Eagle Water Engineering Report (page 9) was $38,115. The projected
cost to complete the Rehabiltation project is $175,100, a 359% increase from previous estimate.
Please explain this discrepancy between the original cost estimate and the projected cost to finish
the project.
Request No. 26: Are there any additional costs expected to be incurred to complete the
Booster Pump Rehabiltation project? If yes, please provide an explanation.
Request No. 27: Please indicate the timeline when this Booster Pump project is
operationaL.
Request No. 28: Please provide an explanation/documentation (i.e. competitive bid
documents, selection process, work contracts, etc.) showing that cost control efforts have been
applied in contracting and/or paying for any of the work elements for rebuilding the booster pump
for Well NO.2.
Well No.8
Request No. 29: It is Staffs understading that Well NO.8 was developed in par to
satisfy the IDEQ mandate for interconnection with an adjacent water system (the Company
selected interconnection with the City of Eagle Water System), and also in par to be able to
service the anticipated growth of Eagle Water customers. Was the design capacity of Well NO.8
oversized to serve the anticipated growth? If yes, please explain assumptions used.
Request No. 30: Please provide cost breakdown for the development of Well NO.8 and
related work into the following categories: a) land purchase (and identify the seller); b) well
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 5 MARCH 24, 2009
driling/development; c) pump and motor d) electrical controls; e) variable frequency drive; t)
appurtenances; g) pump facilty building; h) back-up generator; i) mainline tie-in; and j)
engineering costs.
Request No. 31: Please provide copies of groundwater studies, design reports and
construction plans completed for Well NO.8 (wells, pumping station, back-up generator, mainline
tie-in, etc.).
Request No. 32: Please provide the depth and size (diameter) of Well NO.8.
Request No. 33: Please provide the design capacity of the pump (gpm) and motor size
(hp).
Request No. 34: Please provide an explanation and documentation (competitive bid
documents, selection process, work contracts, etc.) showing that cost control efforts have been
applied in contracting and/or paying for any of the work elements in developing Well NO.8.
Request No. 35: Are there additional costs expected to be incured to complete the
project?
Request No. 36: Please indicate a time line when Well NO.8 is operationaL.
Request No. 37: In reference to Request No. 36, please explain if there are potential issues
that would affect the targeted completion date for Well No.8.
Request No. 38: Please provide a well completion report and ground water right/permit
associated with Well NO.8.
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 6 MARCH 24, 2009
DATED at Boise, Idaho, this t.il day of March 2009.
Donald L. Ho 11, II
Deputy Attorney General
Technical Staff: Gerry D. Galinato
Kathy Stockton
i:umisc:prodreq/eagwæ. Idhgdg prod req I.doc
FIRST PRODUCTION REQUEST
TO EAGLE WATER COMPANY 7 MARCH 24, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF MARCH 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO EAGLE WATER COMPANY, IN CASE NO. EAG-W-09-1,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
ROBERT DESHAZO
PRESIDENT
EAGLE WATER COMPANY INC
172 W. STATE STREET
EAGLE ID 83616
MOLLY O'LEARY
RICHARDSON & O'LEARY
515 N. 27TH STREET
BOISE ID 83707
E-MAIL: molly(ßrichardsonandolear.com
CERTIFICATE OF SERVICE