20210301Suez to Gannon 1-6.pdf

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iii:: iii'ui; -. I *ft l*: 3 iMichael C. Creamer (lSB No.4030)
Preston N. Carter (lSB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
mcc@oiven spurslev.com
prestoncarter@qivenspurslev. com
Aftorneys for SUEZ Water ldaho lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF SUEZ WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE
IN THE STATE OF IDAHO
Case No. SUZ-W-20-02
SUEZ WATER IDAHO INC.'S
RESPONSE TO INDIVIDUAL
INTERVENORS' (GANNON, et. al.)
FIRST COMB!NED DISCOVERY
REQUESTS
SUEZ Water ldaho lnc., ("SUEZ Watef or'Company') submits the following
responses to Individual lntervenors'(Gannon, et. al.) First Combined Discovery
Requests to SUEZ Water ldaho, lnc., dated February 8,2021. Please note that the
responses to Requests for Production Nos. 1 and 2 are confidential and will be
submitted under separate cover per the Commission's rules.
DATED: March 1,2021
SUEZ WATER IDAHO INC.
/ *--:- --. d.-_ Z_*_
By:
Michael C. Creamer
Preston N. Carter
Attorneys for Ap plicant
SUEZ WATER'S RESPONSE TO INDIVIDUAL INTERVENORS'COMBINED FIRST
DISCOVERY REQUESTS.l
15547760_1.DOCX [3G2091
CERTIFIGATE OF SERVICE
I certify that on March 1,2021, a true and conect copy of the foregoing was
served upon all parties of record in this proceeding via electronic mail as indicated
below:
Commission Staff
Jan Noriyuki, Commission Secretary Electronic Mai!
Idaho Public Utilities Commission
11331W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
[e-mail]
Dayn Hardie Electronic Mai!
Matt Hunter
Deputy Attomey General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
davn. [e-mail]
matt. hunter@puc. idaho.qov
lntervening Parties
Ada County:
Lorna K. Jorgensen
John C. Cortabitarte
Ada County Prosecuting Attorney's Office
Civil Division
200 W. Front Street, Room 3191
Boise, lD 83702
liorqensen@adacou ntv. id.qov
ico rta b ita rte@ad acou ntv. i d.qov
CAPAI
Brad M. Purdy
2019 N. 17ft Street
Boise, lD 83702
[e-mail]
lntervenors:
Marty Durand
Piotwrowski Durand PLLC
1020 Main Street, Suite 440
P.O. Box 2864
Boise, lD 83701
[e-mail]
Electronic Mail
Boise City
Scott B. Muir
Deputy City Attorney
Boise City Attorney's Office
150 N. Capito! Blvd.
P.O. Box 500
Boise, lD 83701-0500
boi secitvatto rnev@ citvofbo ise.o rq
Suez Water Customer Group:
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
NSemanko@pa rsonsbehle.com
Boisedocket@ parsonsbehle.com
ldaho Fair House Council, lnc.
Ken Nagy
Aftorney at Law
P.O. Box 164
Lewiston, lD 83501
[e-mail]
SUEZ WATER'S RESPONSE TO INDIVIDUAL INTERVENORS' COMBINED FIRST
DISCOVERY REQUESTS.2
15s47760_1.DOCX [30-209]
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart
555 17th St., Suite 3200
d a ru esch hoff@ hol la nd ha rt. com
[e-mail]
aclee@ holland hart.com
q lqa roa noa mari@ hol la nd ha rt. com
Jim Swier
Greg Harwood
Micron Technology, lnc.
8000 S. FederalWay
[e-mail]
[e-mail]
/ *----: - A_-*_*
Preston N. Carter
SUEZ WATER'S RESPONSE TO INDIVIDUAL INTERVENORS' COTIBINED FIRST
DISCOVERY REOUESTS.3
1 5547760_1.DOCX [3G209]
SUEZ WATER IDAHO INC.
GASE SUZ-W-20-02
INTERVENORS GANNON, ET AL.,
FIRST COMBINED DISCOVERY REQUEST TO SUEZ WATER, INC.
Preparer/Sponsoring Witness: Marsha Il Thom pson
INTERROGATORY NO. 1:
Please estimate the numberof customers located on the Boise Bench who have received
brown water delivered by you. Please describe your method of estimation.
RESPONSE NO. I:
During the four-year period from 2017 to 2020, it is estimated that an average of 137
customers per year notified the Company of discolored water @ncerns. A notable
increase in call volume was seen in 2019 following the Company's public outreach
campaign to encourage reporting.
This estimate is based on the statistical average of discolored water quality calls received
by SUEZ over a four-year period from 2017 to 2020 as shown below.
Year
Discolored Water
Call per Area Notes
2020 87
2019 288
lnitial EFB
Communication
Campaign
2018 94
20'17 79
137 average
90.5 median
suz-w-20-02
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SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
INTERVENORS GANNON, ET AL.,
FIRST COMBINED DISCOVERY REQUEST TO SUEZ WATER, INC.
Preparer/Sponsorin g Witness: Marsha I I Thom pson
INTERROGATORY NO. 2:
Please estimate the number of days in each calendar year (2017 through 2021) Boise
Bench customers have received brown water. Please describe your method of estimation.
RESPONSE NO. 2:
For the four-year period from 2017 to 2020, the Company received customer calls
regarding discolored water an average of 85 days per year. A notable increase in call
volume was seen in 2019 following the Company's public outreach campaign to
encourage reporting.
This estimate is based on the statistical average of discolored water quality ca!!s received
by SUEZ over a four-year period from 2017 to 2020 as shown below.
Year
# Days Discolored
Water Calls were
Received Notes
2020 75
2019 130
lnitial EFB Communication
Campaign
2018 72
2017 62
84.75 average
73.5 median
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Preparer/Spon soring Witness: Marsha ll Thom pson
INTERROGATORY NO. 3:
Please describe any efforts you have made to alleviate, or cure, the brown waterdelivered
to Boise Bench customers.
RESPONSE NO. 3:
To date, efforts to alleviate discolored water in the Boise Bench have included bi-flushing,
operationa! controls, replacement of metallic pipelines, and design of an iron and
manganese treatment facility.
A flushing program on the bench has been performed for the past decade and beyond.
!n 2018, a uni-directional flushing program was introduced to improve the effects of
flushing while minimizing the amount of water needed to flush. Uni-directional flushing is
a systematic approach that concentrates flows, increases velocities, and pushes
discolored water in a controlled manner out of targeted flush points. Beginning in 2019,
uni-directionalflushing has been a bi-annual occurrence used to improve water quality.
Operational controls were implemented to minimize the mixing of different source waters
that could lead to a.discolored water event. This approach limits the use of Vista, Taggart,
and Cassia wells during the winter months. lt also reduces the amount of water that is
coming into the bench, as well as, leaving the bench to maintain a more consistent
pressure and flow through the system.
ln 2019, metallic main was replaced on Overland Stfrom S. Annett St, to S. Loveland St.
ln 2020, six metallic pipelines were replaced at W. Willoway Dr., S. Opal St., S. Pearl St.,
W. Gem St., W. Cherry Ln. from S. Vista Ave. to S. Shoshone St., and S. Allen St. ln
2021, plans are complete and construction will start for mainline replacements for W.
Cassia St. from S. Latah St. to S. Shoshone St., S. Johnson St., and S. Pomander Rd.
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SUEZ WATER IDAHO INC.
cAsE suz-w-20-02
INTERVENORS GANNON, ET AL.,
FIRST COMBINED DISCOVERY REQUEST TO SUEZ WATER, INC
Engineering analysis, piloting, design, and construction bidding has occurred for a new
treatment system at our Taggart Well site located at 1710 S. Taggart St. Engineering
analysis and piloting the wells occurred in 2019, design and permitting were conducted
in 2020, and bidding the project to contractors occuned in January 2021. ln order to
provide a continued supply of water to Bench residents the wells must remain operation
through the months of June through September 1Sth. Therefore, construction is expected
to begin late September.
suz-w-20-02
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SUEZ WATER IDAHO INC.
GASE SUZ-W-20-02
INTERVENORS GANNON, ET AL.,
FIRST COMBINED DISCOVERY REQU EST TO SUEZ WATER, INC.
P repa rer/Sponsorin g Witness: Marshal I Thom pson
INTERROGATORY NO. 4:
Please describe and quantify any rate reduction, or credit, you have provided to Bench
customers for delivery of brown water.
RESPONSE NO.4:
It has been a standard local practice to recommend that any customer experiencing
discolored water concerns should run their fixture for 10-1 5 minutes until clear water flows
consistently. !f conditions following the call do not improve, Company field crews will be
dispatched for further investigation and remedy in the field.
Beginning in April 2019, the Company began offering a $1.50 credit to any customers
experiencing this situation.
Following a customer call with discolored water @noerns, a credit of $1.50 is posted to
their account.
The credit is equivalent to 750 gallons of metered use (or 15 bathtub fills) and is
approximately 10x-15x the recommended volume of a single fixture flushing for 10-15
minutes to clearing temporary discolored water issues.
Records of each call are maintained to identify areas with persistent discolored water.
This infonnation guides work tickets and program efforts for wider system flushing by
utility crews in the field.
Monthly Dollars
Credited
Gallons
CreditedYearTotalAveS egs.so 447,750S szr.so 285,750
$ 22.s0 LL,25O
744,750
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597 49.820L9
2020 381 31.8
15.0202L15
Total 993 Average 32.2 s 1,489.50
SUEZ WATER IDAHO INC.
GASE SUZ-W-20-02
INTERVENORS GANNON, ET AL.,
FIRST COMBINED DISCOVERY REQUEST TO SUEZ WATER, INC.
Preparer/Sponsorin g Witness: Marsha I I Thom pson
INTERROGATORY NO. 5:
Please identify the cause of the brown water delivered to Boise Bench customers and
identify any and all minerals or metals causing the discoloration.
RESPONSE NO.5:
The minerals that cause discolored water are iron and manganese. Both are naturally
occuning minerals common in groundwater sources and are not unique to the SUEZ
water system. Over time the minerals will form a scale on the inner walls of the distribution
pipe. Differing chemistries, changing flow directions, or pressure from the source water
can cause a release in the mineral scale causing a discolored water event.
suz-w-20-02
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Page 1 of 1
Preparer/Sponsori ng Witness: Marshal I Thom pson
INTERROGATORY NO. 6:
PIease describe any plans or surveys you have undertaken or adopted to address or cure
brown water delivery to Boise Bench customers.
RESPONSE NO.6:
Several plans and studies have occurred to identify, mitigate, and eliminate the source of
discolored water. Below is a summary of the efforts taken to date. Several documents
have been produced from these steps and they can be found in the response to
REQUEST FOR PRODUCTION NO. 1 and REQUEST FOR PRODUCTION NO. 2.
Pipe Flushing - the Boise Bench has received annual flushing for the past decade and
beyond. ln 2018, a consultant prepared a uni-directional flushing prcgram specifically for
the east side of the bench. \n2019, bi-annual uni-directionalflushing began and improved
flushing was detected. ln 2021, a consultant prepared uni-directional flushing for the
remainder of the bench out to Cole Rd.
Engineering Studies - in 2019 both internal and external engineering studies occurred
that were used to plan the improvements needed to remove discolored water.
lnternally, our engineering department performed their own assessment and presented
the findings to managers in three separate presentiations. These studies helped guide
the direction and support for moving towards a solution.
A sampling and reporting program was conducted in 2019 that collected water data for
our team and consultant. The results were presented to the City of Boise, Public Utilities
Commission, and the ldaho Department of Environmential Quality (IDEO). The sampling
suz-w-20-02
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SUEZ WATER IDAHO INC.
GASE SUZ-W-20-02
INTERVENORS GANNON, ET AL.,
FIRST COMBINED DISCOVERY REQUEST TO SUEZ WATER, INC.
program included installing six new sampling stations for water quality samples. The
sample data was used by Odell Engineering to assess the problem.
Two consultants (Hansen Allen & Luce and Odell Engineering) were hired to review the
information and provide their opinion of cause for discolored water. Hansen Allen & Luce
are hydraulic modellings experts and provided a map of their findings. Lee Odell with
Odell Engineering is an expert in water quality and authored the book Treatment
Technologies for Groundwater for the American Water Works Association. Mr. Ode!!
provided a written report on the reasons behind the discolored water and
recommendations to improve the water quality.
Operational Plans - a Standard Operating Procedure was prepared for our operations
group to minimize the use of the five wells in the winter time and limit the use of differing
source waters coming into the zone. This plan is followed to minimize system
disturbances.
Pilot Study - a pilot study was done and approved by the IDEQ for treating iron and
manganese at the two TaggartWells. The pilot study showed that a treatment plant could
be effective in removing iron and manganese at the two wells'
Engineering PIans - engineering plans were prepared by Civil Survey Consultants to
replace existing metallic mains that were of the 1940 and 1950 era. Six pipelines were
replaced in 2020.
Design for a new treatment plant occurred in 2020 and included a preliminary engineering
report to IDEQ for approval. Upon completion of the engineering report the design of the
treatment plant for the two Taggart Wells were prepared. The plans are currently at the
IDEQ and City of Boise for final approvals and the project has been bid the Contractors
for the construction of the treatment system to begin this year.
suz-w-20-02
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