20170405Staff 1-27 to GPW.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
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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
IN THE MATTER OF THE APPLICATION OF )
GROUSE POINT WATER COMPANY, LLC rOR)CASE NO. GPW-W-17-01
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR WATER SERVICE IN IDAHO FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
GROUSE POINT WATER
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, request that Grouse Point Water Company
(Company; Grouse Point) provide the following documents and information as soon as possible,
by WEDNESDAY, APRIL 26,2017.
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
FIRST PRODUCTION REQUEST
TO GROUSE POINT
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1 APRIL 5,2017
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
31.01.0r.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. 1: Please list all instances in which the fire pump was activated over
the period 2012tlvough2016. Please include the reason for activation, duration of the
activation, and the quantity pumped.
REQUEST NO.2: Please list all instances in which the Idaho Department of
Environmental Quality was notified that the fire pump was activated.
REQUEST NO.3: Supplemental Schedule #3 states that the fire pump pressure settings
are 40psil70psi, and that the potable water pump uses a VFD set at 60 psi. During its March
20th site visit, Staff observed that the fire pump is controlled using a Variable Frequency Drive
(VFD). Please answer the following questions:
a. Under what circumstances will the fire pump be running, and under what
circumstances will it be completely off?
b. What are the VFD set points for the fire pump?
c. Given its use of a VFD, how is the fire pump turned-offl
d. What is the rationale for using a VFD with the fire pump?
REQUEST NO. 4: How does the Company assure that the fire pump is only operated
during water emergencies as defined by the Idaho Department of Water Resources and the Idaho
Department of Environmental Quality?
REQUEST NO. 5: How does the Company assure that total flow from its pumps does
not exceed the 0.47 cfs limit established by the Idaho Department of Water Resources?
FIRST PRODUCTION REQUEST
TO GROUSE POINT APRIL 5,20172
REQUEST NO. 6: What are the potable water pump high and low pressure seffings?
Under what circumstances will this pump be running, and under what circumstances should it be
completely off?
REQUEST NO. 7: Please provide the make, model, power rating, and pump curves for
all well pumps and motors operated by the Company.
REQUEST NO. 8: What is the power consumed by the potable water pump when used
to maintain system pressure (no water flow)?
REQUEST NO. 9: Please answer the following questions regarding the pressure tank:
a. What is the manufacturer, make, and model?
b. Is it currently being used by the system?
c. What is its capacity?
d. What is its drawdown between the system high and low pressure settings?
e. When was tank pressure last inspected, and what is its pressure when empty?
REQUEST NO. 10: Please provide a list of all Company-owned equipment that
consume electrical power for water service. For each piece of equipment, provide its power
rating and the number of hours that it operates each year.
REQUEST NO. ll: Please list all chemical and biological tests that are required by the
Idaho Department of Environmental Quality for each well.
REQUEST NO. 12: Please list all well tests performed on each pump for the period
2012 through2016.
REQUEST NO. 13: Please provide the manufacturer's recommended periodic
maintenance schedule for both pumps.
FIRST PRODUCTION REQUEST
TO GROUSE POINT J APzuL 5,2017
REQUEST NO. 14: Has the old potable water well been deactivated? If so, please state
how it has been isolated from the system.
REQUEST NO. 15: Has water from the fire well been tested for uranium? If so, when
was the last test performed and what were the results?
REQUEST NO. 16: Supplemental Schedule 3 states that the potable water well
consumes 12,777 kWh per year, and that the fire well consumes 2,200 kWh per year. Billing
information from Idaho Power indicates that the Company annually consumes between 48,000
kWh and 56,000 kWh per year. Please explain the discrepancy.
REQUEST NO. 17: Supplemental Schedule 3 states that the fire pump consumed 2,200
kwh, but only produced 20,000 gallons. Please explain why so much energy was consumed
pumping 20,000 gallons of water.
REQUEST NO. 18: How is hydrogen peroxide metered into the system? How is the
concentration of hydrogen peroxide computed if there are no functioning master meters at the
system?
REQUEST NO. 19: Please provide the manufacturer and model of the hydrogen
peroxide system.
REQUEST NO.20: What is the manufacturers'suggested range of concentration
(specify units) for the hydrogen peroxide system?
REQUEST NO. 2l: The Company's 2015 annual report states that the Company
pumped 1,340,000 gallons of water. The Company's well total for this same year is 1,252,000
gallons. According to Company billing records, the Company sold 2,473,000 gallons in 2015.
Please explain the discrepancies.
FIRST PRODUCTION REQUEST
TO GROUSE POINT 4 APRIL 5,2017
REQUEST NO. 22: In August and September of 2013, the Company used the fire pump
to provide potable water to residents of Grouse Point. Why was the old potable water well,
which the Company maintains as a back-up well, not used for this purpose?
REQUEST NO.23: Please provide an accurate system map showing the locations of
wells, pumps, meters, and other major equipment. Please indicate the locations and diameters of
all pipes and services.
REQUEST NO. 24: Please provide the manufacturer and model number of residential
meters.
REQUEST NO.25: Please provide the manufacturer and model number of all well
metering equipment..
REQUEST NO. 26: Please provide hourly power consumption interval data for the
years2012 through 2016. Data should be provided in EXCEL format. This can be obtained
through Idaho Power's customer service department (reference Zach Harris).
RXQUEST NO. 27: For period 2012 through20l6, please identify and explain specific
instances of extra-ordinary consumption that the Company believes should not be included in
calculation of its billing determinants.
Dated at Boise,Idaho, this ity day of April2OlT.
Deputy Attomey General
Technical Staff: Michael Morrison/l-27
i:umisc:prodreq/gpwwl 7. I bkmm prod req I
FIRST PRODUCTION REQUEST
TO GROUSE POINT 5 APRIL 5,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5ft DAY OF APRIL 2017, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO GROUSE POINT WATER COMPANY, N CASE NO. GPW.W-l7-OI,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TIM FARRELL, P.E.
LISA WANNER
GROUSE POINT WATER COMPANY, LLC
PO BOX 9906
BOISE TD 83707
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE