20170315Staff 8-20 to FLS.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
IN THE MATTER OF'THE APPLICATION OF
FALLS WATER COMPANY,INC. FOR
AUTHORIZATION TO BUILD A NEW WATER
SOURCE, AND ACCESS TO THE SPECIAL
PLANT RESERVE ACCOT]NT
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. FLS-W-17-01
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
FALLS WATER COMPANY,
INC.
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Brandon Karpen, Deputy Attorney General, request that Falls Water Company, Inc. (Company;
Falls Water) provide the following documents and information as soon as possible, by
WEDNESDAY, APRrL 5, 2017.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
SECOND PRODUCTION REQUEST
TO FALLS WATER MARCH I5,2OI71
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. IDAPA
3t.0t.0t.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 8: Please provide a current scaled Falls Water system map showing the
following:
a. Pump/well locations
b. System storage
c. System mains, headers, and primary distribution lines (this information should
provide line size, piping material, and elevations)
d. Hydrant locations
e. Area served by the Company
REQUEST NO. 9: Please provide design parameters for each of the wells and pumps
providing system capacity to the Falls Water system. The requested information for each pump
would include:
a. Pump elevation
b. Pump discharge elevation
c. Design flowrate
d. Maximum allowable flow rate
e. Design discharge pressure
f. Pump curves
REQUEST NO. 10: Please provide a current Falls Water system hydraulic model,
similar to that used by Schiess & Associates in November of 2013, to reflect non-compliance
with Idaho Rules for Public Drinking Water Systems 58.01.08.548.01.b.v and
58.01.08.548.01.b.i. The model scenario of non-compliance should reflect system flows,
pressures, pump operating condition, any points of pressure regulation, and point(s) within the
model of non-compliance. All point(s) of non-compliance should be physically located within
the system.
SECOND PRODUCTION REQUEST
TO FALLS WATER 2 MARCH I5,2OI7
REQUEST NO. 11: Please provide a summary of all well maintenance completed for
the past five years.
REQUEST NO. 12: In the letter from Schiess & Associates dated November 20,2013,
a flow of 2,000 GPM is shown as the requirement for supplying fire flow for Norco. Given that
serving Norco is not relevant in this case, are system upgrades required to resolve pressure issues
and satisfy DEQ pressure requirements? If so, please provide system requirements with Norco
excluded.
REQUEST NO. 13: Has the Company considered any of the following approaches to
resolve non-compliance with Idaho Rules for Public Drinking Water Systems
58.01.08.548.01.b.v and 58.01.08.548.01.b.i? If so, please provide all analysis including
estimated costs:
a. Looping of system piping headers to reduce pressue drop and increase flow
b. Increasing the pipe size ofsystem headers to reduce pressure drop and increase flow
c. Upgrades to existing well pumps to increase pressure and/or flow
REQUEST NO. 14: Please provide all communication, documentation, pricing, and
analysis associated with the proposed "1.5 MG STORAGE TANK & BOOSTER PUMP
STATION ALTERNATIVE" shown on page 3 of Exhibit 3 submitted as part of the Application.
REQUEST NO. 15: Please provide the analysis of all alternatives the Company
considered to resolve non-compliance with Idaho Rules for Public Drinking Water Systems
58,01.08.548.0 1.b.v and 58.01.08.548.01.b.i.
REQUEST NO. 16: Please confirm or identify the units for vertical axis on page 1l of
the Application as pounds per square inch gauge (psig). Additionally, please provide a legend of
all lines represented on the graph.
SECOND PRODUCTION REQUEST
TO FALLS WATER J MARCH I5,2OI7
REQUEST NO. 17: Please confirm or identiff the units for vertical axis on page 12 of
the Application as gallons per minute (gpm). Additionally, please provide a legend of all lines
represented on the graph.
REQUEST NO. 18: Please provide a file that shows actual load growth by customer
type for the last five years.
REQUEST NO. 19: Please provide a file that shows projected load growth by customer
type for the next five years.
REQUEST NO.20: Please provide a file that shows six months (June -November)
daily consumption and pressure data by time of day following the Company's June 22,2016
letter to customers.
Dated at Boise, Idaho, this S+> day of March20l7.
Technical Staff: Rick Keller/S (a-d); 9-ll; 13-17
Kevin Key/ 8 (e); l2; l8-20
i:umisc:prodreq/flsw17. lbkkskrk prod req2
SECOND PRODUCTION REQUEST
TO FALLS WATER 4 MARCH I5,2OT7
CERTTFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15fl' DAY OF MARCH 2017,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FALLS WATER COMPAI\TY, TNC., IN CASE NO.
FLS.W.I7.Ol, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO TIIE
FOLLOWING:
K SCOTT BRUCE
FALLS WATER CO INC
2I8O N DEBORAH DR
IDAHO FALLS ID 8340I
E-MAIL: scottl (Dfallswater.com
CERTIFICATE OF SERVICE