20111019Staff 1-9 to Teton Springs.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
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iû l\ OCl 19 Pl" ,: , ,
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF TETON SPRINGS WATER AND SEWER )
COMPANY LLC, FOR THE APPROVAL OF A )
WATER RATE ASSESSMENT. )
)
)
)
)
CASE NO. TTS-W-11-01
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO TETON SPRINGS WATER
COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Teton Springs Water Company (Teton
Springs Water; Company) provide the following documents and information on or before
WEDNESDAY, NOVEMBER 9, 2011.
This Production Request is to be considered as continuing, and Teton Springs is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil 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
person preparing the document, and the name, location and phone number of the record holder
FIRST PRODUCTION REQUEST TO
TETON SPRINGS WATER 1 OCTOBER 19, 2011
and, if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.1: In reference to Well No.1, please respond to the following
questions:
a. How old is the pumping system (years)?
b. Please provide an assessment of why the pump/motor failed.
c. Please explain why the Company replaced both the pump and the motor (Andrew
Well Driling Invoice No. QII-0605). Did both of them fail?
d. Please explain whether the size and capacity of the pumping unit replaced (gpm
for the pump and hp for the motor) are of the same specification compared to the
size and capacity of the pumping unit recently installed. If not, please explain the
reason(s) why they are different.
e. Please explain why the Company installed a new check valve. (Andrew Well
Driling Invoice No. QII-0605).
f. Please provide a copy of the pump cures for the new and the replaced pumping
units.
REQUEST NO.2: In reference to Well No.2, please respond to the following question.
a. How old is the pumping system (years).
b. Please provide an assessment of why the pump/motor failed.
c. Please explain why the Company replaced both the pump and the motor (Andrew
Well Driling Invoice No. C-5045). Did both of them fail?
d. Please explain whether the size and capacity of the pumping unit replaced (gpm
for the pump and hp for the motor) are of the same specification compared to the
size and capacity of the pumping unit installed. If not, please explain the
reason(s) why they are different.
e. Please explain why the Company installed a new check valve. (Andrew Well
Driling Invoice No. C-5045).
FIRST PRODUCTION REQUEST TO
TETON SPRINGS WATER 2 OCTOBER 19,2011
f. Please provide a copy of the pump cures for the new and the replaced pumping
units.
REQUEST NO.3: The Company indicated that the pumps failed in July and August
2011. Application, page 2. It is Staffs understanding that both pumping units were installed
approximately at the same time when the water system was developed. Please provide an
explanation or your theory as to why both systems failed almost at the same time.
REQUEST NO.4: Please provide any design information concerning the selection and
sizing of the horsepower requirements for both the original pumping units in Well Nos. 1 and 2
(i.e. flow rate, discharge pressure, pumping water depth, etc.).
REQUEST NO.5: Please provide any information concerning frequency of pump
cycling in Well Nos. 1 and 2.
REQUEST NO.6: Please provide any information concerning changes in the pumping
conditions (i.e. pumping water levels, operating or discharge pressures, etc.) for Well Nos. 1 and
2 from the time they were put into service until their failure.
REQUEST NO.7: Please provide an explanation and documentation (competitive bid
documents, selection process, work contracts, etc.) showing that cost control efforts have been
applied in repairing the pump/motor units for Well Nos. 1 and 2.
REQUEST NO.8: In reference to Invoice No. 228 from Teton Water, Inc. dated
8/18/2011, please provide a more detailed explanation of the various tasks included in the
invoice such as Operations September, Well repair ops, Well NO.2 monitoring ops and flushing.
Please provide justification as to why the costs of these tasks were included as par of the
emergency work and not par of the regular operating expenses for the Company.
FIRST PRODUCTION REQUEST TO
TETON SPRINGS WATER 3 OCTOBER 19,2011
REQUEST NO.9: In reference to Invoice No. 8762 from Rendezvous Engineering
dated 8/31/2011, please provide a more detailed explanation of the various tasks included in the
invoice such as drawing for the proposed Well NO.3 and discussions with Mr. Bob Ablondi on
various issues. Please provide justification as to why the costs of these tasks were included as
par of the emergency work and not par of the regular operating expense for the Company.
DATED at Boise, Idaho, this~~ay of October 2011.
ClO~~
Neil Price
Deputy Attorney General
Technical Staff: Gerry Galinato/I-9
i:umisc:prodreq/tswl i.Olnpgdg prod reql
FIRST PRODUCTION REQUEST TO
TETON SPRINGS WATER 4 OCTOBER 19,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF OCTOBER 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TETON SPRINGS WATER COMPANY, IN CASE
NO. TTS-W-II-0l, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
JONPINARDI GENERAL MANAGER
TETON SPRINGS WATER &
SEWER COMPANY LLC
3940 GRAND STREET
DRIGGS ID 83422
E-MAIL: jpinardi(fsilverstar.com
".6~SECREiARY~ ~
CERTIFICATE OF SERVICE