20170413Staff 1-13 MNV.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
ISB NO. 8743
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
MORNING VIEW WATER COMPANY INC.
FOR DEFERRAL AND RECOYERY OF COSTS
ASSOCIATED WITH WELL SYSTEM
FAILURE.
CASE NO. MN'V-W-16-02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
MORNING VIEW WATER
COMPANY, rNC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Sean
Costello, Deputy Attorney General, requests that Moming View Water Company, Inc. ("Morning
View" or "Company") provide the following documents and information as soon as possible, but no
later than THURSDAY, MAY 4,2017.
The Company is reminded that responses pursuant to Commission Rules of Procedure must
include the name and phone number of the 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. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Morning View 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.
FIRST PRODUCTION REQUEST
TO MORNING VIEW WATER
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1 APRIL I3,2OI7
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 identify the name, job title, location and telephone number of the
record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a schedule showing all expenditures related to the well
failure and flood at the well house to date. Please include invoices and other supporting
documentation.
REQUEST NO. 2: Please provide a schedule showing estimates of all expenses expected for
the well failure and flood at the well house. Please provide supporting documents for those expenses.
(Contractor estimates, proposals, etc.)
REQUEST NO. 3: Please provide a schedule showing detailed time records by employee of
time spent to date on the resolution of the well failure and flood provided by employees of the
Company. Please include hours by work descriptions.
REQUEST NO. 4: The Company indicated warranty claims and possible legal action were
being explored. Please provide an update.
REQUEST NO. 5: Please provide a system map showing the location of major equipment
including wells, pipes, storage tanks, booster pumps, shut-off valves, meters, and water treatment
equipment as the system was configured immediately prior to the incident. Include pipe sizes, storage
tank volumes, and pump horsepower.
REQUEST NO. 6: Please provide the make and model of each pump that was connected to
the system. Include pump curves for each pump.
FIRST PRODUCTION REQUEST
TO MORNING VIEW WATER
2 APRIL I3,2OI7
REQUEST NO. 7: Please provide the applicable written emergency procedures that were in
place at the time of the incident. Were these procedures followed? If not, please explain.
REQUEST NO. 8: Please identifu systems that can be used to isolate, or shut-off each pump
at the time a line failure occurs. Describe how each was used during the incident.
REQUEST NO. 9: Please confirm that only the New Pump was operating at the time of the
incident. If this is not correct, please identify each pump that was actually in operation.
REQUEST NO. l0: Please provide the upperilower pressure limit switch settings, or variable
speed drive settings, for each pump that was in operation.
REQUEST NO. 11: Please identify and explain how the system is supposed to detect and
notify the operator of a line break. Please include the criteria that the system used to identif line
break (low pressure limit, high flow, etc).
REQUEST NO. 12: For the flange and pipe section that failed, please provide the following
information:
a) The type (e.g. welded, compression) and size of flange (make and model if available).
Include the pressure rating for this flange.
b) Gasket material that was used to seal this flange.
c) The type of pipe that was connected to this flange. Please identify the coating that was
used on this pipe. Include the pressure rating for this pipe.
d) A description of the means used to connect the flange to the pipe. Provide a sketch or
photographs if possible.
e) The installation and maintenance history of this particular flange and pipe section.
Please identify the individual or organization that last performed work on this flange
and pipe section.
FIRST PRODUCTION REQUEST
TO MORNING VIEW WATER
J APRIL I3,2OI7
REQUEST NO. 13: Please describe all actions that have been taken since the incident in
order to ensure that a similar incident does not occur in the future. Please include, but not limited to
a) Changes to the pumps or pump controller settings.
b) Changes to plumbing and shutoff valves.
c) Changes to the system used to alert the operator in the event of an emergency.
d) Changes to the flange and pipe that failed.
/3/2.Dated at Boise, Idaho, this day of April2017
Sean Costello
Deputy Attorney General
Technical Staff: Joe Terry (l-4)
Mike Morrison (5-13)
i:umisc:prod req/mnvwl6.2scjtmm prod req I
FIRST PRODUCTION REQUEST
TO MORNING VIEW WATER
4 APRIL L3,2OI7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I TIAVE THIS 13th DAY OF APRIL 2017,
SERVED THE FOREGOING X'IRST PRODUCTION REQUEST OX' THE
COMMISSION STAFF TO MORNTNG \rIEW WATER COMpAt[y INC., IN
CASE NO. MNV.W.I6.O2, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
NOLAN GNEITING PRESIDENT
MORNING VIEW WATER CO
PO BOX s98
zuGBY ID 83442
E-MAIL : rnornin gviewater(@ gmail. com
SECRET
CERTIFICATE OF SERVICE