20230728FLS to Staff 77.PDF

FALLS WATER CO., INC.’S RESPONSES TO SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 1 OF 2
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[16867532_1.DOCX]

Attorneys for Falls Water Co., Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF FALLS WATER CO., INC. FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
IN THE STATE OF IDAHO

Case No. FLS-W-23-01

FALLS WATER CO., INC.’S RESPONSES
TO SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF

Falls Water Co., Inc., (“Falls Water,” “Applicant,” or “Company”) in response to the
First Production Request of the Commission Staff to Falls Water Co., Inc. dated July 6, 2023,
submits the following responses.
DATED July 28, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Attorneys for Falls Water Co., Inc.
RECEIVED
2023 JULY 28, 2023 4:41PM
IDAHO PUBLIC
UTILITIES COMMISSION
FALLS WATER CO., INC.’S RESPONSES TO SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on July 28, 2023, I caused to be served a true and correct copy of the
foregoing document to the person(s) listed below by the method indicated:
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
_________________________________________
Preston N. Carter
Rates & Regulatory Affairs
FLS-W-23-01
In the Matter of Falls Water Company's Application for Authority to Increase its Rates
and Charges for Water Service
Data Request Response
Preparer/Responding Witness:
Scott Bruce
General Manager, Falls Water Company, Inc
[phone]
Request No.: FLS-W-23-01 IPUC DR 77
In Staff attachment A FLS W 23 01 lines 29, 30, & 31, please explain why Well 10 had a
Chlorinator rebuilt on 3/31/20 in the amount of $2,509.35 and then 2 new chlorinator
pumps were purchased in August and September for $479.23 and $556.22 respectively.
Response:
The chlorinators for the wells used granular chlorine. The chlorination station had a
mixing tank and would automatically mix the chlorine solution in the tank. The granular
chlorine would be sucked into the tank and mixed with water. The system functioned to
expectations initially. However, over time the vacuum system would clog with the
granular chlorine due to humidity in the wellhouse. The vacuum motors failed with
increasing regularity. This would create issues with the mixture of chlorine solution
being injected into the water system.
The Company’s staff would check the chlorination stations at each well daily and correct
any problems. In redesigning the chlorination stations, the Company reverted to hand
mixing the chlorine solution in the mixing tanks on the chlorination station. The
3/31/2020 project cost is the original redesign of the chlorine station.
In August 2020, the pump was not replaced, rather a flaw in the design for mixing the
chlorine solution was corrected. The harsh chemical environment corroded the metal
fasteners used on the mixing wheel in the chlorine solution tank. Alternate materials
were found that would withstand the contact with the chlorine.
In September 2020, the injector pump, which was the original pump for the chlorinator
station failed. The injector pump was replaced on September 13, 2020, with a new
pump.
The Company made every effort to utilize the existing chlorinator station parts when
redesigning the station.
FLS-W-23-01
IPUC Staff DR 77
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