20210107Staff 1-4 to Teton Water.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
II33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
TETON WATER & SEWER COMPANY FOR
RESERVE FUND DISTRIBUTION
CASE NO. TTS.W.2O.Oz
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
TETON WATER AND SEWER
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, requests that Teton Water and Sewer Company
("Teton Water" or "Company") provide the following documents and information as soon as
possible, but no later than THURSDAY, JANUARY 28, 2021.
This Production Request is to be considered as continuing, and Teton Water 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 or information 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 WATER AND SEWER JANUARY 7,2021
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and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.o1.o1.228.
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 all available photos of the repair projects included in
this Application.
REQUEST NO. 2: In reference to the 37 Targhee Trail repair project, please respond to
the following:
a. What caused the Company to look for a leak at this location?
b. Was the new leak detection equipment used to find the location of the leak? If so,
how accurate was the leak detection equipment in locating the location of the
leak? If the leak detection equipment was not used, how was the leak located and
why was the leak detection equipment not used?
c. Did the inaccurate depth on the As-Built plans cause an increase in the cost for
this repair? If so, please explain how it affected the cost.
d. Please describe how the curb stop became damaged.
REQUEST NO. 3: In reference to the 2 Curtis Circle repair project, please respond to
the following:
a. Please explain and provide evidence of how this repair project satisfies the
parameter established in Order No. 30718 that requires the reserve fund to be used
only for emergencies and major unplanned capital expenditures (plant repair,
maintenance and replacement).
b. Did the silt issue present a water-quality issue that could affect the health of those
occupying the residence? If so, please provide any evidence that this was the
case.
FIRST PRODUCTION REQUEST
TO TETON WATER AND SEWER
c. Did the Company find the root cause of the silt issue?
d. Please describe and provide a drawing illustrating the "unique connection to the
mainline" prior to installing a new service line resolving the silt issue.
2 JANUARY 7 ,2021
e. Why does this home have a unique connection to the mainline?
f. Why did the silt issue take approximately 9 months to resolve?
g. Are there any other unique connections like 2 Curtis Circle on the Company's
system? If so, is there potential for this situation to happen at the other locations?
REQUEST NO. 4: In reference to the 20 Blackfoot Trail repair project, please respond
to the following:
a. Please explain and provide evidence of how the 20 Blackfoot Trail repair project
satisfies the parameters established in Order No. 30718 that require the reserve
fund to be used only for emergencies and major unplanned capital expenditures
(plant repair, maintenance and replacement).
b. Please explain how the Company plans to better locate curb stops in the future to
avoid large excavation projects.
c. Please explain how the Company is ensuring that the As-Built plans are updated
when the Company finds errors in the plans.
DATED at Boise, Idaho, this ilL auy of Jantary 2021
Lt
Edward J
Deputy A General
i:umisc:prodreq/ttsw20.2ejme prod req I
FIRST PRODUCTION REQUEST
TO TETON WATER AND SEWER JANUARY 7 ,20273
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7M DAY OF JANUARY 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TETON WATER AND SEWER COMPANY, IN CASE
NO. TTS-W-20-02, BY E- MAILING A COPY THEREOF, TO THE FOLLOWING:
JON PINARDI
TETON WATER & SEWER CO
PO BOX 786
DRIGGS D 83422
E-MAIL: [e-mail]
Tetonws @ silverstar.com
YS
CERTIFICATE OF SERVICE