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HomeMy WebLinkAbout200501051st Response of United Water 1 to 8.pdfORIGINAL Dean J. Miller McDEVITT & MILLER LLP 420 West Bannock Street O. Box 2564-83701 Boise, ill 83702 Tel: 208.343.7500 Fax: 208.336.6912 ioe~mcd~-miller.com Idaho Public Utilities Commission Office of the SecretaryRECEIVED JAN - 5 2005 Boise, idaho Attorneys for Applicant BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF UNITED WATER IDAHO INC. FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO Case No. UWI-O4- UWID'S FIRST RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST COMES NOW United Water Idaho Inc. , (" United" , " the Company ) and responds to Request Numbers 1 through 25 28 and 29 of the First Production Request of the Commission Staff. Dated this of January, 2005. McDEVITT & MILLER LLP UWID's RESPONSE TO STAFF'S FIRST PRODUCTION REQUESTS-1 UNITED WATER IDAHO INC. CASE UWI-O4- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer and Sponsoring Witness: Gregory P. Wyatt Telephone: (208)-362-7327 Title: General Manager REQUEST NO. Please explain why UWI is increasing its investment in the Bali Hai and Maple Hills wells when both appear to have relatively poor water quality. RESPONSE NO. United Water Idaho is investing in both the Bali Hai and Maple Hills wells precisely because they have a less than desirable water quality. Both of these facilities are being equipped with green sand filtration in order to enable United Water to more fully utilize the supply that is available from those wells. Bali Hai well has a capacity of approximately 2400 gallons per minute (gpm), but due to its lower water quality (iron, manganese, and ammonia) has been operated at about 800 gpm so as to avoid incurring customer complaints about water quality. Maple hills well has a capacity of approximately 2000 gallons per minute (gpm), but due to its lower water quality (iron, manganese, and ammonia) has been operated at about 1000 gpm so as to avoid incurring customer complaints about water quality. With the addition of the green sand filtration systems at these two well sites, United Water is able to fully utilize the well' capacity to satisfy customer demands with high quality water. UNITED WATER IDAHO INC. CASE UWI-O4- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer and Sponsoring Witness: Gregory P. Wyatt Telephone: (208)-362-7327 Title: General Manager REQUEST NO. Please discuss whether the $3.5 million spent to add storage facilities to the former South County system was considered in the purchase of the system by UWI. Was the purchase price of the South county system adjusted to account for needed additions of storage facilities? Please provide analysis showing why additional storage facilities were needed in the South County area. RESPONSE NO. The $3.5 million for additional storage referenced in my testimony was for three separate storage projects of which only $1.465 million relates to the South County storage facilities. Additional storage on the South County system was considered in the acquisition as evidenced in Direct Testimony of Keith E. Stokes, reference p. 4, lines 10- and Direct Testimony of Randy Lobb, reference p. 4, lines 6-, and p. 9 , lines 14- 19. The need for additional storage in the South County system area appears to have been clearly understood during the Commission s deliberations on and ultimate approval of the South County acquisition. The Commission approved purchase price for the acquisition was determined to be appropriate based on the evidence presented in that filing. The South County area pressure zone is a growing area that includes over 6,000 customers and contained no water storage facility, and thus insufficient fire protection capability, prior to the construction of the new storage facility. Storage sizing calculations include volume to meet daily peak customer demands plus a reserve volume for fire protection needs. United Water normally calculates the peaking volume by multiplying the maximum day usage for the service area by 170/0. The Recommended Standards for Water Works more commonly referred to as the Ten States Standards recommends a more conservative approach where the peaking storage equals the average day customer demand. These two methods result in the following peaking volumes , based upon 2002 water usage in the South County service area: United Water method - 1.210 million gallons Ten States method - 2.913 million gallons Adding the fire protection reserve of 1.080 million gallons (4 500 gpm for 4 hours) results in total storage volumes of: United Water method - 2.290 million gallons Ten States method - 3.993 million gallons The South County storage facility was sized at 2.5 million gallons in order to serve the customers' maximum daily needs while holding sufficient water in reserve to support fire protection. UNITED WATER IDAHO INC. CASE UWI-O4- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Scott Rhead Telephone: (208) 362-7345 Title: Managing Engineer REQUEST NO. Please provide a copy of pertinent sections of any reports or analysis from the Treasure Valley Hydrologic Project to support your testimony on southeast Boise groundwater condition. RESPONSE NO. The following web site locations provide support for the testimony on Southeast Boise groundwater conditions. Water Level Change Map can be accessed at: !J!!p://www.idwr.state.id.us/tvallev/qround water/qw levels.htm Scroll down to groundwater level change map (Water Level Changes 1969/76- 2000 ) Southeast Boise Groundwater Management Area hydrographs data can be accessed at: !J!!p:/ /www.idwr.state.id.us/hydroloqic/inf%bswell/default.htm Click on Southeast Boise GWMA The IDWR Open File Report: "Groundwater Management Areas in Idaho- Overview as of 1998" can be accessed at: !J!!p:/ /www.idwr.state.id.us/hydroloqic/info/pubs/ofr/ofr -qwma rQtQQf SEBGWMA discussed on pg. 55- UNITED WATER IDAHO INC. CASE UWI-O4- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Scott Rhead Telephone: (208) 362-7345 Title: Managing Engineer REQUEST NO. Reference p., lines 13-21. On what is the Company relying to project/expect future growth south of the airport? How much growth is expected and over what time frame? Which customers/areas are now generally being served by well facilities developed as part of the Southeast Boise Water Supply project? there currently capability to pump more water from these wells? RESPONSE NO. In the early to mid 1990's the area south of the airport on the Ten Mile Ridge was planned for development with applications made to Ada County. Terms of the agreement for securing the well sites for the Pleasant Valley and Ten Mile wells in 1995 included language stating, "Subsequent to the receipt of all appropriate governmental approvals , Tenant (United) shall provide water service to the PVD Property and the Black Creek Property (the development area) for domestic, commercial , industrial , irrigation and fire protection purposes." Shortly after the execution of this agreement, United filed and received approval for the addition of their proposed development to United's service area. At that time, it appeared the development would be initiated within the next three to five years. Since then , the economy and development trends have slowed the progress of this project. However, regardless of the actual timetable for the development , United is obligated to serve this property and must reserve the water supplies necessary. Approximately 3000 homes are estimated with this development. Water produced from the Ten Mile wells is used to support customers in the Columbia Village , Gowen, Surprise Valley and Barber service areas. Some the water is also transferred north along Federal Way and piped into the Main Service Level (downtown area) at Garfield St. Very little or no additional water can be pumped from the Ten Mile area wells. Due to deep static water levels in this area groundwater temperatures are only slightly below "low temperature geothermal" as defined by IDWR. The potential to lower the pumps in the Ten Mile area wells is minimal due to the subsurface conditions specific to this area. (Also see response to number 5). UNITED WATER IDAHO INC. CASE UWI-O4- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Scott Rhead Telephone: (208) 362-7345 Title: Managing Engineer REQUEST NO. Reference p. 7, lines 1-13. Provide any studies or analysis to support the testimony concerning the "strength" of the aquifer system and its inability to produce water for export to another area. RESPONSE NO. See attached document: -- United Water Memo dated 2/24/03 and attached water level graphs. This memo reevaluated the groundwater alternatives described in the 1998 Master Plan but also addressed drilling additional wells within the Columbia Service Level. It was recommended that additional monitoring be done to confirm the apparent stabilization or decreasing rate of non-pumping water level decline observed in the Ten mile Ridge wells. It can take a few to several years to see the full response from changes in pumping (for example in the SBGWMA where shallower wells are still declining while water levels in deeper wells are stabilized in response to decreased local pumping. UNITED WATER IDAHO INC. CASE NO. UWI-W-O4-04 FIRST PRODUCTION REQUEST IPUC STAFF TT A C H MEN T RESONSE TO REQUEST NO. United Water 1("e. (jj) United Water 8248 W. Victory Rd. Boise, 10 83709 telephone 208 362 7358 facsimile 208 362 3858 Memo DATE:February 24, 2003 TO:Scott Rhead FROM:Roger Dittus SUBJECT:Reevaluation of groundwater alternatives outlined in 1998 UWID Master Plan The Master Plan prepared for United Water Idaho by Montgomery Watson in 1998 provided planning recommendations based on technical and economic analyses. Options for source of supply based on groundwater and surface water were compared. Two groundwater source scenarios (designated alternative GWI and GW2) are described. Each groundwater alternative proposes drilling new wells to supplement groundwater production from existing wells and redrilling/ reconstructing some existing wells for greater production or to obtain higher water quality. GWI adds wellhead water treatment facilities at several well sites so that production from sources with less than desirable water quality can be maximized. GW2 incorporates no groundwater treatment and proposes greater development of new wells. When complete GWI would result in an addition of 21.8 MGD from new wells. Alternative GW2 would result in an additional 35 MGD from new wells. The increase over present Maximum Day production from wells corresponds to 28 percent for GWI and 45 percent for GW2. A description of the hydrogeologic framework underlying each UWID Service Level was provided to Montgomery Watson in December of 1997. Specific groundwater quality and quantity constraints known to exist in each Service level were outlined in order to estimate availability of new groundwater sources. It was assumed that additional wells could be added within UWID' s service area so that well density would approximate the maximum well density existing in other portions of UWID' s Service Area. UWID' s recommendations took into account known water quality and production constraints associated with the aquifer at certain locations within UWID's Service Area. For planning, it was assumed that only 60 percent of the estimated maximum well density should be applied. This is resulted in the quantity of new groundwater source expressed in alternative GW2. Lately, the assumption was made that a new well in the Boise Area would produce 1.4 MGD and a new well in the Eagle area was assumed to be capable of producing 2.1 MGD. ONDEO Services Five additional years of observations (1998 to 2003) from UWID production and monitoring wells have led to a better understanding of the number of production wells that can be sustained. Also important has been data collected by entities such as the Southeast Boise Groundwater Management Area Committee, and the Treasure Valley Hydrologic Project (TVHP). The Master Plan s Executive Summary notes that the TVHP, which will address the issue of defining sustainable yield, had not yet es.timated a "safe yield" from the aquifer. Significant progress has been made by the TVHP with regards to groundwater flowpaths ages, interaction between aquifers , and recharge sources , etc. However, the "safe yield" from the deeper aquifer which supplies the majority of UWID wells has not been determined. Sufficient water level data exists to suggest that withdrawing an additional 37 MGD on top of current well production from within UWID's Service Area is not practical. The lower rate of 21.8 MGD used in the Master Plan s alternative GW1 is also now thought to represent an overly optimistic estimate with respect to sustainable yield. An example using development in UWID's Columbia Service Level (CSL) is appropriate to illustrate this point. In the groundwater alternatives outlined in the Master Plan, new wells in this service level account for a large percentage of the increase in source. There are presently four production wells located on Tenmile Ridge, in UWID's CSL. These were drilled between 1994 and 1998. At the time when the Master Plan was released there were only three wells in the CSL and these wells had a relatively short production history of between 1 and 4 years. Aquifer testing in 1996 suggested that well interference would not be a factor limiting production in this area. During this test pumping well water levels approached stabilization while observation well water levels showed little drawdown due to pumping. However, over the last five years it has been observed that while well interference does not in fact limit production during seasonal peak production, water levels in area wells have declined. Measurements of non-pumping water levels in the Tenmile Ridge wells show a decline of approximately 10-to-12 feet since 1994. The Raptor well, the first of the Tenmile Ridge wells has declined by an average of 1.4 feet per year. Due to their proximity to UWID' Tenmile Ridge wells, water levels in domestic wells located to the north of and just below Tenmile Ridge have been periodically documented. Some of these domestic wells withdraw groundwater from the same elevation as the Raptor well, the nearest UWID well. The trends in non-pumping water levels measured in most domestic wells approximate the declines observed i~ UWID's Tenmile Ridge wells. Shallower domestic wells also have declined likely, as a result of there own pumping as well as due to UWID and other non-domestic wellproduction. To date, the ability of nearby domestic users to withdraw water has not been impacted. Additionally, water level data for the Raptor well indicate that little or no water level decline has occurred since 1998 when the most recent Tenmile Ridge well (Pioneer well) was completed. Although if seven additional wells were drilled in the Tenmile Ridge area (as under the Master Plan groundwater alternatives), a tripling of the present withdrawal would result. It is reasonable to conclude that at a minimum a tripling of water level decline (or at least 35 feet in comparison to 1994 water levels) would soon result, thus forcing a curtailment of production by limiting drawdown. If a pressure change of this magnitude propagated throughout the aquifer, at least some domestic wells may need to have there pumps lowered. It is also possible that some domestic wells may have to be deepened. Therefore, a 200 percent increase of withdrawals from the CSL, as would occur if GW11 GW2 were implemented is not believed to be feasible. It is recommended that continued monitoring of water level response to production from the existing wells on Tenmile Ridge be done before additional wells are constructed. It may be justified to enlarge the Southeast Boise Groundwater Management Area to the west to include portions of the Gowen Service Level and CSL. In summary, since UWID's 1998 Master Plan was compiled, estimates of the volume of groundwater that can be obtained as additional source for future needs has been reevaluated. As illustrated in the preceding example, the groundwater supply in the Tenmile Ridge area appears to be capable of supplying the existing wells, but not as many as was proposed in the groundwater alternatives described in the Master Plan. Besides the Tenmile Ridge area, other locations have been identified as not practical for increasing well production as proposed in the Master Plan. Water level declines in production wells have occurred over the previous few decades throughout many parts of UWID' s Service Area. For example, declines of a few feet to several tens of feet have occurred beneath theBoise Bench, along the New York Canal, and of course the Southeast Boise Groundwater Management Area. It has been found that the production rate of many wells has declined at the same time that the water level has declined to reach an apparent equilibrium. Recently, estimates of average yearly decline were made for all UWID wells in the contiguous system.If the assumption is made that the average linear declines will continue into the future, and that the resulting loss in drawdown capacity can be translated into a corresponding loss of production capacity (using individual well specific capacity) the following prediction isobtained. By 2020, UWID' s existing production wells will be capable of a Maximum Day capacity of 62 MG. The present Maximum Day production is about 77 MG. Applying a linear decline to the water level changes in UWID' s production wells is somewhat simplistic but does illustrate that building a dependency on a 28 percent to 45 percent increase over present groundwater production is not optimal. UNITED WATER IDAHO INC. CASE NO. UWI-W-O4-04 FIRST PRODUCTION REQUEST IPUC STAFF ATTACHMENT TO RESONSE TO REQUEST NO. 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CASE UWI-O4- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Scott Rhead Telephone: (208) 362-7345 Title: Managing Engineer REQUEST NO. Please explain or theorize why peak day demand for 2004 was so much less than for the previous four years as shown on page 9 of your testimony. RESPONSE NO. The level of peak day customer use is closely related to temperature and precipitation. The records indicate that consumption correlates with temperature increasing by about an MGD per degree rise in temperature during late July and early August. The year 2004 was somewhat unique in that the average temperature for the first ten days of July was 88.5 degrees, whereas the years 2000 through 2003 averaged 92.9 degrees for the same period. In addition eight days later, a major rain event occurred totaling 0.59" (July 18, 2004 - July , 2004), with an associated drop in temperature of 9 degrees. Production responded with a drop of 18.2 MGD from July 18 to July 20. The combination of a cooler start for the month and the rain event is the most apparent explanation. of the reduction in peak day compared to the previous four years. UNITED WATER IDAHO INC. CASE UWI-O4- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Scott Rhead Telephone: (208) 362-7345 Title: Managing Engineer REQUEST NO. Reference p. 11 , lines 8-10. Please provide reports , correspondence or other information documenting DEQ's "adoption of a program to allow compliance by source management and concentration averaging." Identify those UWI wells that currently do not meet arsenic limits. RESPONSE NO. DEQ is responding to EPA'Arsenic Treatment Technology Evaluation Handbook for Small Systems (EPA 816-03-014). This document provides an overview of several approved arsenic treatment technologies. It states the following regarding "Seasonal Use 2 Seasonal Use Another option is to switch a high arsenic water source from full-time production to seasonal use or peaking use only. When used, it would be blended with low arsenic water sources before entry to the distribution system. This is allowed at the federal level, as long as the running annual average at the entry point to the distribution system does not exceed the MCL. Pg. 12 , paragraph 2.Arsenic Treatment Technology Evaluation Handbook for Small Systems (EPA 816-03-014). All wells currently are below the 50 ppb limit and meet current arsenic limits. The five wells that will not meet the 2006 arsenic limit of 10 ppb are Terteling, Market Bergeson , Central Park and Warm Springs Mesa #3. UNITED WATER IDAHO INC. CASE UWI-O4- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Scott Rhead Telephone: (208) 362-7345 Title: Managing Engineer REQUEST NO. Does UWI currently have any plans to implement Aquifer Storage and Recharge using water from the CWTP? If so, please describe or provide a copy of those plans. RESPONSE NO. United Water has a preliminary plan to construct an Aquifer Storage and Recovery (ASR) well in the vicinity of the Columbia WTP. The capital plan designates funding in 2006 for permitting and pilot well activities. The production well (1 MGD) would be completed in 2007, based on need and subject to successful results and agency approvals. United has obtained water right permit #63-31409 from Idaho Department of Water Resources which allows for ground water recharge with water diverted from the Boise River.