20171025Staff 1-5 to Teton 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
J D14 C.t,; 1-.r-- v
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BBFORB THE TDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
TETON WATER & SEWER COMPANY, LLC
TO RECOVER EXPENSES FOR A THIRI)
WELL.
CASE NO. TTS.W.17.O1
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
TETON WATER & SEWER
COMPANY, LLC
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, request that Teton Water & Sewer Company, LLC
(Company; Teton 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 TETON WATER
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1 ocToBER 25,2011
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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
31.0r.0t.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. l: Please provide a system map showing the location of existing major
equipment including wells, pipes, storage tanks, booster pumps, shut-off valves, meters, fire
hydrants, and water treatment equipment. 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, and capacity of each pressurized storage tank.
d. The make, model, and capacity 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: Please provide a system map showing the location of the proposed
new well, including any pipes, storage tanks, booster pumps, shut-off valves, meters, and water
treatment equipment associated with the new well.
REQUEST NO.3: Please list and explain alternatives to drilling a new well that were
considered by the Company. Explain why drilling a new well was preferable to each of these.
REQUEST NO. 4: Please provide any engineering and geological reports used by the
Company to determine the location for the new well.
REQUEST NO. 5: Please provide copies of all invoices paid for the research and
development of the new well.
FIRST PRODUCTION REQUEST
TO TETON WATER 2 ocroBER 25,2077
Lffi^rof october 2017Dated at Boise, Idaho, this
Technical Staff: Michael Morrison/1-4
Joe Terry/5
i:umisc.prodreq/ttswl 7. I bkmmjt prod req I
FIRST PRODUCTION REQUEST
TO TETON WATER
Brandon
Deputy Attorney General
fi-
aJ ocroBER 25,20t7
CERTIFICATE OF SERVICB
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF OCTOBER 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TETON WATER & SEWER COMPANY, LLC, IN
CASE NO. TTS-W.I7-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
JON PINARDI
TETON WATER & SEWER CO
PO BOX 786
DRIGGS ID 83422
E-MAIL : Tetonrvs(*)si I ver:star'.con'r
SECRETARY
CERTIFICATE OF SERVICE