20220411Staff 31-46 to Teton Water.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. II2O2
Street Address for Express Mail:
1 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
TETON WATER & SEWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR WATER SERVICE IN THE
STATE OF IDAIIO.
CASE NO. TTS-W.22-02
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO TETON WATER AI\D
SEWER COMPAII"Y
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attorney General, requests that Teton Water and Sewer Company
("Company") provide the following documents and information as soon as possible, but no later
than MONDAY, MAY 2,2022.
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO TETON WATER AND SEWER
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I APRIL II,2O22
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO.3l: Please provide a thorough and complete description of the current
water system. This should include any deficiencies that can be identified that need to be
addressed to maintain system integrity and to support growth, as well as any
changes/investments that the Company plans to implement to address deficiencies relative to
items included below. Include the costs and benefits for any investments or increases in
expense.
a. Processes and methods. This should include processes involved in the delivery of
water and business processes (i.e., billing, maintenance, customer support, etc.);
b. Manpower/staffing, including the amount of labor and the level of
expertise/experience ;
c. Equipment/infrastructure/software both direct (i.e., pipes, tanks, and pumps) and
indirect (maintenance equipment, computers, etc.);
d. Policies and standards (i.e., service level, maintenance turnaround time, etc.); and
e. Materials (productive material used for water quality, spare parts inventory, etc.).
REQUEST NO.32: Please provide a current system map showing the location and
elevation of 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, 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; and
f. The make, model, and capacity of all water treatment equipment.
SECOND PRODUCTION REQUEST
TO TETON WATER AND SEWER 2 APRIL II,2O22
REQUEST NO.33: Please provide construction installation drawings for the current
water system including:
a. Plan drawings;
b. Section drawings;
c. Detail drawings;
d. Specifications (materials, components, and equipment); and
e. Installation requirements.
REQUEST NO. 34: Please provide a hydraulic model of the system showing the results
for each of the following operating scenarios: (l) low flow condition; (2) peak hour condition;
and (3) maximum day plus fire flow condition. Please include the following information for
each resulting scenario:
a. A distribution system graphical representation showing the primary components (i.e.,
pumps, wells, storage, pipe network, and users);
b. Primary component parameters (elevation, size, horsepower, operating curve);
c. Piping segment materials, lengths, and diameters;
d. Piping nodal elevations; and
e. Operating scenario parameters:
i. Nodal pressures;
ii. Piping segment flows;
iii. Pump operating parameters;
iv. Well static water level; and
v. Storage tank level.
REQUEST NO. 35: If the system includes a fire prevention system, please provide the
following:
a. The name and contact information for the fire authority who prescribes requirements
for the system; and
b. Fire flow and storage requirements prescribed by the fire authority.
SECOND PRODUCTION REQUEST
TO TETON WATER AND SEWER J APRIL II,2O22
REQUEST NO. 36: Please provide information related to the capacity and sizing of the
system and the ability of the system to meet historical and future system peak demand.
Information would include not only capacity/constraints of/in the system, but also consumption
and consumption at peak periods.
REQUEST NO.37: Please provide the most recent Idaho Division of Environmental
Quality Sanitary Survey.
REQUEST NO.38: Please provide the Idaho Division of Environmental Quality
Licensed System Operator who will be responsible for the operation and maintenance of the
system, please provide the following information:
a. Name;
b. License Number and Class; and
c. Business Address.
REQUEST NO.39: Please provide the Idaho Department of Water Resources Water
Right Numbers (basin and sequence number) for each water right used by the system.
REQUEST NO. 40: For each well in the water system, please provide the following:
a. The Idaho Department of Water Resources Well Tag Number (D-Tag Number)
currently on-file with IDWR;
b. Location (Township, Range, Section, and Tract); and
c. The well log.
REQUEST NO. 41: Please provide all studies, reports, or regulatory requirements
stating the need for a new third and fourth well.
REQUEST NO. 42: Please provide all contractor bid proposals for the installation of
any new well.
SECOND PRODUCTION REQUEST
TO TETON WATER AND SEWER 4 APRIL II,2O22
REQUEST NO. 43: Please provide monthly flow rate data for each system well pump
and each booster pump during the past three years.
REQUEST NO. 44: Please provide monthly electric bills for each system well pump
and each booster pump during the past three years. These bills would show monthly energy use
(kVfh) and peak energy demand (kW).
REQUEST NO.45: Please provide information related to the capacity and sizing of the
system and the ability of the system to meet historical and future system peak demand. This
information should include not only capacity information, but also any constraints within the
system to meet peak demand. Please also provide information on average consumption,
consumption at peak periods, and future forecasted consumption.
REQUEST NO. 46: Please provide details of the Company's system leaks (i.e., count,
location, line size, expected cause of failure) and explain the method for repairing the leak to
prevent a future leak.
DATED at Boise, Idaho, this ( lfl auy of April2022
Riley Newton
Deputy Attorney General
i:umisc:prodreq/ttstw22.2mrk prod req 2
SECOND PRODUCTION REQUEST
TO TETON WATER AND SEWER 5 APRIL II,2O22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I ITH DAY OF APRIL 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO TETON WATER AI\D SEWER COMPAI\IY, IN CASE
NO. TTS-W-22.02, BY E. MAILING A COPY THEREOF, TO THE FOLLOMNG:
JON PINARDI
TETON WATER & SEWER CO
PO BOX 786
DRIGGS TD 83422
E-MAIL: [e-mail]
Tetonws@ silverstar. com
J. f,,Z,.r\
SECRETARY /
CERTIFICATE OF SERVICE