20210623Staff 17-23 to FLS.pdf

Street Address for Express Mail:
I1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTTLITIES COMMTSSION
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF FALLS WATER CO.,
INC.'S APPLICATION FOR APPROVAL OF
THREE CAPITAL PROJECTS: T) CREATION
oF A NEW WATER SOURCE,2)
CONSTRUCTION OF A STORAGE TANK, AND
3) CONSTRUCTTON OF A WELLHOUSE
cAsE NO. FLS-W-21-01
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO FALLS WATER COMPANY
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Falls Water Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JULY 14, 2021.
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 telephone number of
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO FALLS WATER 1 JUNE 23,2021
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 17: Please provide the modeling results for each scenario (i.e. low flow
condition, peak hour condition, and maximum day plus fire flow condition) considered in
Section 2.3.5. Hydraulic Model Analysis of Existing System of the 2019 Drinking Water Capital
Facilities Plan. Please include the following information for each scenario:
a. A distribution system graphical representation showing the primary components (i.e.
pumps, wells, storage, pipe network, and users);
b. Primary component parameters (elevation, size, horsepower, operating curve);
c. Piping segment materials, lengths, and diameters;
d. Piping nodal elevations; and
e. Operating scenario parameters
i. Nodal pressures
ii. Piping segment flows
iii. Pump operating parameters
iv. Well static water level
v. Storage tank level.
REQUEST NO. 18: Please provide the modeling results for each scenario (i.e. low flow
condition, peak hour condition, and maximum day plus fire flow condition) of the "future water
system" considered in Section 3.4 Hydraulic Model Analysis of the 2019 Drinking Water Capital
Facilities Plan Please include the following information for each scenario:
a. A distribution system graphical representation showing the primary components (i.e.
pumps, wells, storage, pipe network, and users);
b. Primary component parameters (elevation, size, horsepower, operating curve);
c. Piping segment materials, lengths, and diameters;
d. Piping nodal elevations; and
e. Operating scenario parameters
i. Nodal pressures
ii. Piping segment flows
iii. Pump operating parameters
iv. Well static water level
v. Storage tank level.
SECOND PRODUCTION REQUEST
TO FALLS WATER 2 JUNE 23,2021
REQUEST NO. l9: Please provide the modeling results for the "future water system"
considering "Alternative I with Storage Tank" for each scenario (i.e. low flow conditions, peak
hour conditions, and maximum day plus fire flow conditions) in Section 3.4 Hydraulic Model
Analysis of the 2019 Drinking Water Capital Facilities Plan. Please include the following
information for each scenario:
a. A distribution system graphical representation showing the primary components (i.e.
pumps, wells, storage, pipe network, and users);
b. Primary component parameters (elevation, size, horsepower, operating curve);
c. Piping segment materials, lengths, and diameters;
d. Piping nodal elevations; and
e. Operating scenario parameters
i. Nodal pressures
ii. Piping segment flows
iii. Pump operating parameters
iv. Well static water level
v. Storage tank level.
REQUEST NO.20: Please provide the modeling results for the "future water system"
considering "Alternative 2 with Additional Well and No Storage Tank" for each scenario (i.e.
low flow conditions, peak hour conditions, and maximum day plus fire flow conditions) in
Section 3.4 Hydraulic Model Analysis of the 2019 Drinking Water Capital Facilities Plan. Please
include the following information for each scenario:
a. A distribution system graphical representation showing the primary components (i.e
pumps, wells, storage, pipe network, and users);
b. Primary component parameters (elevation, size, horsepower, operating curve);
c. Piping segment materials, lengths, and diameters;
d. Piping nodal elevations; and
e. Operating scenario parameters
i. Nodal pressures
ii. Piping segment flows
iii. Pump operating parameters
iv. Well static water level
v. Storage tank level.
SECOND PRODUCTION REQUEST
TO FALLS WATER J JI.INE 23,2021
REQUEST NO.21: Please provide the rationale for determining the placement and size
for the 2.0 million-gallon (MG) storage tank adjacent to Well #9 identified as "Altemative I with
Storage Tank". Please provide the analysis and any workpapers in electronic format with
formulas intact.
REQUEST NO.22: Please provide the Company's planned schedule for completing the
remaining drinking water improvements shown in Table 7 - Projects Addressing Existing
Deficiencies of the 2019 Falls Water Company Drinking Water Capital Facilities Plan.
REQUEST NO. 23: Regarding transitioning the Falls Water system into a two-pressure
zone system:
a. Please provide the analysis and justification for a two-pressure zone system.
b. Please explain why the 2019 Drinking Water Capital Facilities Plan does not
address transitioning the Falls Water system into a two-pressure zone system.
DATED at Boise, Idaho, this day ofJune 2021.L*
Deputy Attorney General
i: umisc:prodreq/fl sw2 l. I dhrk prod req 2
SECOND PRODUCTION REQUEST
TO FALLS WATER 4 JUNE 23,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF JUNE 2021,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMITyIISSION STAFF TO FALLS WATER COMPAI\Y, N CASE NO.
FLS-W.21.0I, BY E-MAILING A COPY THEREOF, TO THE FOLLOMNG:
PRESTON CARTER
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
harmonywri eht@ givenspursley. com
ERIC W NELSEN
SR REGULATORY ATTORNEY
NWNATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-MAIL : [e-mail]
K SCOTT BRUCE
FALLS WATER CO INC
2180 N DEBORAH DR
IDAHO FALLS ID 8340I
E-MAIL: [e-mail]
,L,1-Ar-.,
CERTIFICATE OF SERVICE