20171025Staff 1-7 to Rickel Water.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
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
RICKEL WATER COMPANY TO COMBINE
WITH BITTERROOT WATER COMPANY, INC.
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
RICKEL WATER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, request that Rickel Water Company (Company;
Rickel Water) provide the following documents and information as soon as possible, but no later
than WEDNESDAY, NOVEMBER 15, 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, and 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 zuCKEL WATER
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CASE NO. RIC-W.I7.OI
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ocToBER 25,20171
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
31.01.01.228.
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 provide a system map showing the location of major
equipment including wells, pipes, storage tanks, booster pumps, shut-off valves, meters, fire
hydrants, and water treatment equipment. Please identify the components that currently are part
of the Rickel system, and those that are part of the Bitterroot system. Please include the
following information :
a. The make, model, and rating of each well pump.
b. The make, model, and rating of each well pump motor.
c. The make, model, capacity, and limit switch settings of each pressurized storage tank.
d. The make, model, capacity, and limit switch settings of each unpressurized storage
tank/reservoir.
e. The make, model, and rating of each booster pump.
f. The make, model, and capacity of all water treatment equipment.
REQUEST NO. 2: It is Staffs understanding that in normal operation, the Rickel well
and pump are not used, and that the Bitterroot well and pump are used to pressurize both the
Rickel and Bitterroot systems. Is this correct?
REQUEST NO. 3: It is Staffs understanding that the Rickel well and pump can be used
as a backup source for both the Rickel and Bitterroot systems, but that it does not have sufficient
capacity to meet the combined peak demand from both systems. Please confirm this
understanding. Under what conditions would the Rickel system be unable to meet the combined
demands of both systems?
FIRST PRODUCTION REQUEST
TO RICKEL WATER 2 ocToBER 25,2017
REQUEST NO. 4: Please respond to the following questions:
a. What is the peak demand on the Rickel system?
b. What is the peak demand on the Bitterroot system?
c. What is the peak capacity of the Rickel system?
d. What is the peak capacity of the Bitterroot system?
REQUEST NO. 5: Please provide the fire flow and storage requirements used to design
the Bitterroot system.
REQUEST NO. 6: Can the Rickel and Bitterroot systems be operated simultaneously?
REQUEST NO. 7: Please provide total sales volume data (in gallons) by customer for a
three-year period in Excel format.
L#o^,Dated at Boise, Idaho, this of October 2017
Karpen
Deputy Attorney General
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Technical Staff: Michael MorrisorVl-6
John Nobbs/Bentley Erdwurm/7
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FIRST PRODUCTION REQUEST
TO RICKEL WATER J ocToBER 25,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF OCTOBER 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO RICKEL WATER COMPANY, IN CASE NO.
RIC-W-17-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
KEN RICKEL
OWNER & MANAGER
RICKEL WATER COMPANY
PO BOX 126l
HAYDEN LAKE ID 83835
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SECRETART_
CERTIFICATE OF SERVICE