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HomeMy WebLinkAbout20150715UWI to Staff 34-37,43,49-58.pdf(208):i4$7s00 (208) 33669t2 (Far.) McDevitt & Miller LLP Lawyers 420 West Baonock Steet P.O. Box ?5*83701 Boiser ldaho 83702 CheB. F. McDerritt DeanJ. (foe) Millet Celeste trL Millet Yia llaad Delircty & US Mail JeaoJeweil, Secrctary Idaho Public Utilities Commission 472W. Washingtoa St Boise,Idaho 83720 July 15,2015 C J --1 t* i- '11'-- '--i Re: [IS[I-W-15-01 Deat Ms.Jewell: Enclosed for filing, please find an odgind and thtee (3) copies of United Watet I.laho's Third Response to the Commission Staffs Second Production Request Nos. No. 34,35,36,37,43,49, 5A, 51,52,53,54,55, 56,57 aod 58. Response to Request No. 52 is ptovided in electtonic fotmat oo ao enclosed disk Kiodly tetum a file sramFed copy to me. Very Truly Yours, McDevitt & MillerLLP Sauru^ DeanJ. Millet DJM/hh Cc: Uoited Water Idaho, Inc. t\)e t:t't t* llt r" -'(Jl fi T -.: -5 o(, ORIGINAL Dean J. Miller (lSB No. 1968) McDEVITT & MILLER LLP 420 West Bannock Street P.O. Box 2564.-83701 Boise, lD 83702 Tel: 208.343.7500 Fax 208.336.6912 ioe@mcdevitt-m iller. com Attomey for United Water ldaho lnc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION lN THE MATTER OF THE APPLICATION I Gase No. UW-W-15{1 OF UNITED WATER IDAHO INC. FOR AUTHORIry TO INCREASE ITS RATES I UNITED WATER IDAHO'S THIRD AND CHARGES FOR WATER SERVICE I RESPONSE TO SECOND IN THE STATE OF IDAHO PRODUGTION REQUEST OF THE COilIIUISSION STAFF United Water ldaho lnc., ("United Wate/') by and through its undersigned attorneys, hereby submits its Third Response to the Commission Staffs Second Production Request Nos. No. 34, 35, 36, 37, 43, 49,50, 51, 52, 53, 54, 55, 56, 57 and 58. DATED this \K_day of July, 2015. UNITED WATER IDAHO'S THIRD RESPONSE TO SECOND PRODUCTION REQUEST OF THE coiltitilsstoN STAFF - 1 Attomey for United Water ldaho lnc. CERTIFIGATE OF SERVICE I hereby certify that on tne -!5ftay of July,2015, I caused to be served, via the method(s) indicated below, true and correct copies of the foregoing document, upon: Jean Jewell, Secretary ldaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, lD 83720-0074 iiewell@puc.state. id. us Donald L. Howell, ll Daphne Huang Deputy Attorney Genera! ldaho Public Utilities Commission P.O. Box 83720 Boise, ldaho 83720-0074 don. howell@ puc. idaho. sov daphne.huano@puc. idaho.qov Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise, lD 83702 bmpurdv@hotmail.com Hand Delivered U.S. Mail Fax Fed. Express Email Hand Delivered U.S. Mail Fax Fed. Express Email Hand Delivered U.S. Mail Fax Fed. Express Email K (J 'TJ LI !l K (-a .-i x tl I-t TJ N UNITED WATER IDAHO'S THIRD RESPONSE TO SECOND PRODUCTION REQUEST OF THE coiriilsstoN STAFF - 2 UNITED WATER IDAHO INC. CASE UWI-W.15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 34: Please explain the reasons for the Company's proposed Rule 44 changes. RESPONSE NO.34: The Company's proposed Rule 44 change to separate all fire service line connections from potable service lines relates to several concerns. This change recognizes the Company's long practice of requiring service line separation between potable and fire service functions. The size and function of these services is quite distinct. The majority of fire service lines in the system have been sized at a large diameter to meet required fire protection needs. The larger size of fire service lines would rarely be appropriate for the secondary use of potable water consumption due to meter accuracy constraints at relative volumetric flow rates. Smaller and more appropriately sized service lines are installed with a meter for that purpose. Finally, in the interests of public safety, the Company will not typically turn off fire services for any reason other than a customer needing to make repairs. ln the case of an account requiring a shut off for non-payment, our current practice of requiring separation on service lines allows for a potable line closure without compromising the customer's available fire protection. UNITED WATER IDAHO INC. GASE UW|-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 35: What are UWI's policies regarding disconnection and reconnection of residential fire service customers? What policies, in particular, pertain to disconnection of residential fire service customers for non-payment of either their residential or fire service water bills? RESPONSE NO.35: The Company has no separate procedure for "residential fire service customers". The procedures outlined here would apply to any customer, residential or othenrvise, with fire service from the Company. The Company will not typically turn off fire service for any reason other than a customer needing to make repairs. lf a customer calls to stop service because they are moving, and the same water account includes a fire service, the Company would read the domestic water meter and turn it off. Account billing for the fire service would be put on hold, while the physical fire service would remain active for fire protection purposes. The case of a fire service requiring a shut off for non-payment is quite rare. ln fact, the Company does not have record of such an event occurring in recent memory. The process outlined below would pertain to disconnection of a fire service customer for non-payment of the bill for that service. lf a fire service account required shut off due to would be contacted to set up a payment plan. The Company will make every effort to contact numbers and addresses listed on the account. non-payment, the customer the customer given phone 1. 2. Page 1 of 2 3. 4. 5. UNITED WATER IDAHO INC. cAsE uwr-w-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF lf the customer can be reached, the Company would attempt to make a payment plan for the past due charges. lf the event a customer cannot be reached, the Company would leave a blue tag on the door for the customer to call the Company office by a certain date. lf that deadline is not met, the Company would contact the Fire Marshall and inform him/her of the proposed termination date for the property. The Company would then put the account into the collection process and follow rules 302.01 (Failure to Pay), 304.01 (lnitial Notice), 304.02 (Final Notice), and 304.03 (Additional Notices if applicable). Page 2of 2 UNITED WATER IDAHO INL. CASE UWI.W.15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 36: According to the National Fire Protection Association, 'NFPA 13D is a residential spdnkler design standard focused on one- and two-family dwellings and manufactured homes. The intent is to provide an affordable sprinkler system in homes while maintaining a high level of life safety." a. Would the Company's proposed Rule 44 change apply to multiple use customers who wish to install an NFPA 13D compliant system? lf so, how would the Company's proposed Rule 44 changes affect residential customers' ability to take full advantage of the cost savings afforded under NFPA 13D? b. For customers wishing to install sprinkler systems conforming to NFPA 13D, what would be the incremental costs associated with the Company's proposed rule changes? RESPONSE NO.36: The Company's proposed Rule 44 change would not apply to customers who wish to install a NFPA 13D compliant fire sprinkler system in a service line size of one-inch or smaller that could adequately provide required volumetric flow for fire protection as determined by the Fire Marshal (ie. standard one- or two-family dwellings, or manufactured homes). Given that the Company's proposed rule change would not apply to NFPA 13D compliant residential fire sprinkler systems, there would be no incremental cost adjustment to customers from the proposed rule change. UNITED WATER IDAHO INC. GASE UW!-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 37: How many residential fire service customers does the Company currently have? How many new residential customers applied for fire service in 2012,2013,2014, and 2015 to present? RESPONSE NO. 37: The Company currently has 139 active service agreements for residential unmetered fire connections. The following list shows the count of residential customers who applied for fire service in the years 2012to present. Year Customer Count 2012 2 2013 26 2014 13 2015 6 UNITED WATER IDAHO INU. GASE UWI-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Roger Greaves/Kevin Doherty REQUEST NO. 43: Please provide the pro-forma (i.e., as described by the Company) plant additions and retirements on a monthly basis (See Application, Greaves Dl Exhibit 3). RESPONSE NO. 43: Please refer to Company Exhibit 1 1, Schedule 3. UNITED WATER IDAHO INC. CASE UW!-W-l5-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson EEIIUEL}!o.+II: Please provide a summary of new service inspections showing when turn-on orders are received for new or previously inactive service connections, including cross-connection assembly, backflow assembly, and initial testing inspections. Also provide the number of times the Company has turned off new water services and/or issued notifications to the Plumbing lnspector to stop issuance of occupancy permits for the years 2013 and 2014. As part of your response, please provide an example of this type of correspondence. EEENM9: This process for new service inspections takes place in two phases with minor variances depending on service size. For the size range one-inch and smaller, construction acceptance is performed as part of the final sub-division job-walk review at the end of a longer period of project inspection. The Company's review of cross connection hazard for the sub-division takes place in the early phases of planning and design acceptance. The final job-walk confirms construction is completed to pre-approved plan sets. At the conclusion of the job-walk, smaller services are still not active (lacking a meter). The second phase of the process for final service connection takes place when a customer calls to establish service. Following this call, a field service order is issued to place a meter for final service. For services larger than one-inch in diameter, the service inspection is performed as part of final construction acceptance. Services of this size are installed with a pre-set meter and padlock locking the service valve closed position. The lock is removed when an individual a customer call to establish service. The Company is later contacted by the local plumbing inspector for its Cross Connection Specialist to ride-along for the final certificate of occupancy inspection. The Company has not issued a notification to the Plumbing lnspector to stop issuance of an occupancy permit in the years 2013 or 2014. UNITED WATER IDAHO INL. CASE UWI-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 50: Please provide a summary of the Company's existing Connections Service lnspections Program including: a. Service area prioritization strategy and rationale; b. Number of staff assigned; c. When the program was first initiated, when significant process or requirement changes were made to the program and a summary of what those changes were. RESPONSE NO.50: The prioritization for service inspections in the service area as determined by the local potential for cross connection hazard. The Company requires some form of backflow protection on all commercial service lines. Greater focus is placed on industrial, medical, and manufacturing facilities due to their nature of use and hazard potential. For residential connections, higher priority is given to areas with access to alternate irrigation water sources. These alternate sources are often pressurized. Meaning, a simple pump setting change in-excess of Company system pressure would be sufficient to cause a reversal of flow from a non-potable source into the public water supply without protection. The lowest priority is placed on residential service connections supplying lawn sprinkler systems with Company potable water service. The main concern in these locations is a phenomena known as 'reverse siphonage' in the event of a system depressurization on the Company side of the service due to main break or fire demand. Without adequate backflow protection, such conditions can allow contaminants to enter the public water supply via home plumbing or irrigation systems. Page 1 of2 UNITED WATER IDAHO INC. CASE UWI-W-I5-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF The Company Cross Connection Control Program currently has 5 employees assigned to its administration in various capacities. The program was initiated in 1980 with an initial focus on high hazard commercial service connections. Significant changes were made to the program in 2013 following multiple residential cross connection related incidents. The primary emphasis of the 2013 program change was a focus on premise isolation of backflow hazards from the public water supply. Page 2 of 2 UNITED WATER IDAHO INL. CASE UW!-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 51: Please provide a detailed description of the current inspection process including: annual and long-term work planning, pressure zone or specific neighborhood selection and prioritization, field activities, field inspection forms, customer correspondence prior to field work, customer correspondence following field work, and the results of the inspections program for 2013,2014, and the first half of 2015. RESPONSE NO. 51: Since 2013 the Company's inspection process has focused on the area South and West of Victory Rd. between Eagle Rd. and S.Cole Rd. in our certificated area. This area covers the previously acquired 'South Count Water System'where the existence of a previous Cross Connection Program is not known. The area has pressurized alternate irrigation water available to home owners, posing a cross connection threat to the public water system if not properly protected. As a standard practice, customers are not contacted prior to inspection. The Company inspector goes to the door to notify the customer of his intent to inspect the property for a cross connection, or verify the proper backflow assembly is present and has been tested. lf the customer is not at home, the inspection still takes place. No further contact is made if the property has no issues. lf an issue is found, the inspector will leave a door tag describing the problem with details for the customer to contact the inspector. Most issues can be corrected without service interruption, however the inspector may immediately terminate service to a property during his inspection if a dangerous condition to public health is found to be present. Most customers respond by phone to set up a meeting at their property. The majority of issues are resolved at this point without sending a formal Determination Letter. Page 1 of2 UNITED WATER IDAHO INL. CASE UW|-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF The inspector documents all activities using a mobile handheld computer in the company GIS system. Attached you will find customer correspondence examples: "2013-2015 Notice of Determination Letters.pdf', "2013 Notice of Termination Letters.pdf', and "Cross Connection Customer Door Tag.pdf used for scheduling follow up customer meetings. Page 2 of 2 United Water ldaho Case UW-W-15-01 UNITED 1q/ATER IDAHO CROSS CONNECTION CONTROL PROGMM PO BOX 190420 BOISE, ID 83719 WWW. U NITEDWATER.COM/I DAHO/BACKFLOW Request No. 51 Attachment 1 Page 'l of 2 Nick Robinson 11630 W. Oneida Dr. Boise, Idaho 83709 September 13, 2013 CROSS CONNECTION CONTROL PROGRAM NOTICE OF INTENT TO TERMINATE SERVICE Dear Mr. Roblnson, You have failed to make the corrections identified in the "Notice of Determination" dated August 13, 2013 mailed to you, The Pressure Vacuum Breaker backflow assembly at your residence is not installed and tested according to State Plumbing codes. It is installed below ground in a box and has not been tested. A Pressure Vacuum Breaker must be installed above ground at a height of 12 inches above the highest sprinkler head. You were first notified back on Tlt$lt3 with a door tag making you aware of the corrections required. The United Water Idaho Inc. Rules and Regulations provide United Water Idaho with the authority to terminate servlce'In the event a backflow assembly ls required, it shall be lnstalled, malntained and tested at the customert expense. Fallure to properly install, maintain or test the required devise will result in termination of serulce to the customer ln accordance the IPUC's Customer Relations Rules and Regulatlons" or if necessary to prevent a violation of federal, state or local safety or health codes. (Ref: IDAPA 31.21,01, Rule 303) Your lnaction is deemed a threat to public health. As a result, water service to the following address will be turned off after9:00 am on the date listed below. Service Address: 11630 W. Oneida Dr. Boise, Idaho Shut Off Date: September 23,2013 The followlng actlon can be taken to avoid termination:r Contact Unlted Water Idaho with proof of proper lnstallatlon and testlng by a state licensed backflow tester. r Contact United Water Idaho to verifo physical disconnectlon from the cross connection hazard. United Water ldaho Case U\M-W-15-01 UNITED WATER IDA}IO CROSS CONNECTION CONTROL PROGMM PO BOX 190420 BOISE, ID 83719 WWW. UNITEDWATER.COM/IDAHO/BACKFLOW Request No. 51 Attachment 1 Page 2 ol 2 If you remain unsatisfied with the Company, you may file a complalnt with the Idaho Publlc Utllities Commlsslon, PO Box 83720, Boise, ID 83720-0369, (208) 334- 0369. UNITED WATER IdAhO DENNIS FICKES PROGMM ADMINISTMTOR CROSS CONNECTION CONTROL PROGMM PO BOX L90420 BOISE, ID 83719 TEL 208-362-7304 WWW. U NITEDWATER. COM UDAHO\BACKFLOW United Water ldaho Case UW-W-15-01 UNITED X+ITATER IDAHO CROSS CONNECTION CONTROL PROGMM PO BOX190420 BOISE, rD,837L9 TEL 208-362-7304 WWW. U NTTEDWATER. COM\IDAHO\BACKFLOW Nick Robinson 11630 W. Oneida Dr. Boise, Idaho 83709 August 13, 2013 UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Request No. 51 Attachment 2 Page 1 of8 Dear Mr. Robinson, If has been determined by United Water ldaho the Pressure Vacuum Breaker backflow assembly at your residence is not installed and tested according to State Plumbing codes. A Pressure Vacuum Breaker must be installed above ground 12" above the highest sprinkler head. If you want your backflow assembly installed below ground in a box you would have to use a Double Check Valve Assemble. A door tag was left at your residence on7lt8ll3 by our Cross Connection Control Specialist making you aware of the corrections required. He revisited your property on B/6/L3 and the corrections have not been made. This Notice of Determination is meant to notify you of the requirement for the correct installation and testing of your back flow assembly on your sprinkler connection from your service line. Failure to comply with this notice will result in denial or termination of water service to your property. Please contact Bill Thompson our Cross Connection Control Specialist at 362-7383 or myself at 352-7382 with any questions. Yours sincerely, UNTTED TVATER DENNIS FICKES PROGRAM ADMINISTRATOR CROSS CONNECTION CONTROL PROGRAM PO 8OX190420 BOISE, ID, 83719 TEL 208-362-7304 WWW, UN ITEDWATER.COM\IDAHO\BACKFLOW Page 1 United Water ldaho Case UWI-W-15-01 UNITED I.IIATER IDAHO CROSS CONNECTION CONTROL PROGRAM PO BOX190420 BOISE, ID, 83719 TEL 208-362-7304 WWW. UNITEDWATER.COM\I DAHO\BACKFLOW Steve Cady 5120 W. Cherry Ln. Meridian, Idaho 83642 April23,20L4 Request No. 51 Attachment 2 Page 2 of 8 UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Dear Mr. Cady, It has been determined by United Water Idaho that your property at 3181 W. Alpine St. Alplne Wheel Estates is require to have premise backflow protection. This is required to protect the public drinking water supply from contamination from potential backflow. You are required to lnstall a Double Check Valve Assembly behlnd the meter box on your side of the water service line, With the assembly installed, it will be your responsibility to have a state licensed Backflow Tester perform an initial test on the assembly, and send the result to United Water Idaho. Annual testing will be an ongoing required following the initial test. On 4ll4l20t4 our Cross Connection Control Specialist, Stacy Stuart, contacted you by phone making you aware of this requirement. United Water ldaho's regulatory authority for enforcement of its Cross Connection Control Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho Public Utilities Commission (IPUC) Rules and Regulations. Please have the backflow assembly installed and test by 5/5/t4. Failure to comply with this notice will result in denial or termination of water service to your property. Please contact Stacy Stuart at 362-7383 or myself at 362-7382 with any questions. Yours sincerely, UNITED I',IATER DENNIS FICKES PROGRAM ADMINISTRATOR CROSS CONNECTION CONTROL PROGRAM BOISE, ID, 83719 TEL 208-362-7304 WWW. UN ITEDWATER. COMU DAHO\BACKFLOW Page 1 United Water ldaho Case UW-W-15-01 UNITED itrATER IDAHO CROSS CONNECTION CONTROL PROGRAM PO 8OX190420 BOISE, ID, 83719 TEL 208-362-7304 WWW. UNITEDWATER.COMUDAHO\BACKFLOW Steve Cady 5120 W. Cherry Ln. Meridian, Idaho 83642 May 5, 2014 UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Dear Mr. Cady, Request No. 51 Attachment 2 Page 3 of 8 You contacted me by phone on 4/301t4 and asked for an extenslon until the end of May to install the Double Check Valve assembly required on the servlce line of your property at 3181 W. Alplne St. ln Boise. I agreed to an extension until May 30, 2014. By this extension date you will have the assembly installed and tested and the test results sent to Unlted Water. You stated your contractor Mlke Rlce Excavatlon was not available until after the middle of May because he was tied up on a project in Meridian. United Water Idaho's regulatory authority for enforcement of its Cross Connection Control Program fall under the Idaho Rules for Public Drinking Water (iDAPA) 58.01.08 administered by the Idaho Department of Environmental Quallty, Uniform Plumbing Codes and the Idaho Public Utilities Commission (IPUC) Rules and Regulations. Please contact Stacy Stuart, Unlted Water's Cross Connection Control Specialist at 362-7383 when the backflow assembly is lnstalled and tested. Yours slncerely, UNTTED !^qATER DENNIS FICKES PROGRAM ADMINISTRATOR CROSS CONNECTION CONTROL PROGMM BOISE, ID, 83719 TEL 208-352-7304 WWW. U N TTEDWATER. COM\IDAHO\BACKFLOW Page 1 United Water ldaho Case UW-W-15-01 UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM PO BOX190420 BOISE, ID, 83719 TEL 208-362-7304 WWW. U NITEDWATER.COMUDAHO\BACKFLOW Request No. 5'1 Attachment 2 Page 4 of 8 Dennis Geving 5550 S. Lapwai Pl. Boise, tdaho 83709 April t7, 2075 UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Dear Mr. Geving, It has been determined by Unlted Water Idaho that your property at 5550 S. Lapwai Pl. is required to have irrlgation backflow protection or the plumbing fixture for the backflow assembly removed. This is required to protect the public drinklng water supply from contamination from potential backflow. You are required to reinstall a Reduced Pressure Backflow Assembly behind the meter box on your side of the water service line. With the assembly installed, it will be your responsiblllty to have a state licensed Backflow Tester perform an initial test on the assembly and send the result to Unlted Water ldaho. Annual testlng wlll be requlred followlng the lnitial test. The second option is to dig up and remove the sprinkler maln valve, drain valve and standpipe for the backflow assembly from the domestic water line. On 4/28/20L4, 613/t4, 9/6/L4 and 2/7/t5 our Cross Connection Control Speclalist, Stacy Stuart, contacted you by phone making you aware of this requirement. United Water Idaho's regulatory authority for enforcement of its Cross Connectlon Control Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho Public Utllltles Commlssion (IPUC) Rules and Regulations. Please have the backflow assembly installed and tested or the plumbing fixture removed by5/tlt5. Failure to comply with thls notlce will result in denialortermination of waterserulce to your property. Please contact Stacy Stuart at 362-7383 or myself at362-7382 with any questions. Yours sincerely, UNITED VfATER DENNIS FICKES PROGRAM ADMINISTRATOR CROSS CONNECTION CONTROL PROGMM BOISE, ID, 83719 WWW. U NITEDWATER.COMUDAHO\BACKFLOW Page 1 United Water ldaho Case UWI-W-15-0'l UNITED LAIATER IDAHO CROSS CONNECTION CONTROL PROGRAM PO BOX190420 BOISE, ID, 83719 TEL 208-362-7304 WWW. UNITEDWATER.COM\IDAHO\BACKFLOW Melissa Bryson 10681 W. Mohawk Pl. Boise, Idaho 83709 April 21, 2015 Request No. 51 Attachment 2 Page 5 of 8 UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Dear Mrs. Bryson, It has been determined by United Water Idaho that your property at 10941 W. Mohawk Pl. is required to have lrrigation backflow protection or the plumbing fixture for the backflow assembly removed. This is required to protect the public drinking water supply from contamination from potential backflow. You are required to install a Reduced Pressure Backflow Assembly behind the meter box on your slde of the water service line. With the assembly installed, it will be your responsibility to have a state licensed Backflow Tester perform an initial test on the assembly and send the result to United Water Idaho. Annual testing will be required following the initial test, The second option is to dig up and remove the sprinkler main valve, drain valve and standpipe for the backflow assembly from the domestic water line, On 8/t5/20t4, 9/301t4, 7OlL3/14 and 7tl3/74 our Cross Connection Control Specialist, Stacy Stuart, contacted you with a door hanger, in person or by phone making you aware of this requirement. United Water Idaho's regulatory authority for enforcement of its Cross Connection Control Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho Public Utilities Commission (IPUC) Rules and Regulations. Please have the backflow assembly installed and tested or the plumbing fixture removed by 514/L5, Failure to comply with this notice will result in denial or termination of water service to your property. Please contact Stacy Stuart at 362-7383 or myself at352-7382 with any questions. Yours sincerely, UNITED WATER DENNIS FICKES PROGMM ADMINISTRATOR CROSS CONNECTION CONTROL PROGMM BOISE, ID, 83719 Page 1 United Water ldaho Case UWI-W-15-01 UNITEO TS,JATER IDA}IO CROSS CONNECTION CONTROL PROGMM PO BOX190420 BOISE, ID, 83719 TEL 208-362-7304 WWW. UN ITEDWATER.COMU DAHO\BACKFLOW David Cullison tOB74 W. Onondaga Dr. Boise, Idaho 83709 April 21, 2015 Request No. 51 Attachment 2 Page 6 of 8 UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Dear Mr. Cullison, It has been determined by United Water Idaho that your property at 10874 W. Onondaga Dr. is required to have irrigatlon backflow protection or the plumbing fixture for the backflow assembly removed. This is required to protect the publlc drinking water supply from contamination from potential backflow. You are required to reinstall a Reduced Pressure Backflow Assembly behind the meter box on your side of the water service line. With the assembly installed, it will be your responsibility to have a state licensed Backflow Tester perform an initial test on the assembly and send the result to United Water Idaho. Annual testing will be required following the initial test. The second option is to dig up and remove the sprinkler main valve, draln valve and standpipe for the backflow assembly from the domestic water line. On 8/2812074, 9ll5lt4, 9/22/14 and 10/13/14 our Cross Connection Control Specialist, Stacy Stuart, contacted you with a door hanger, in person or by phone making you aware of this requirement, United Water Idaho's regulatory authority for enforcement of its Cross Connection Control Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho Public Utilities Commission (IPUC) Rules and Regulations. Please have the backflow assembly installed and tested or the plumbing fixture removed by 5/4/L5. Failure to comply with this notice will result ln denial or terminatlon of water service to your propefi. Please contact Stacy Stuart at 362-7383 or myself at362-7382 wlth any questions, Yours sincerely, UNITED IO,TATER DENNIS FICKES PROGRAM ADMINISTMTOR CROSS CONNECTION CONTROL PROGRAM BOISE, ID, 83719 Page 1 United Water ldaho Case UW-W-15-01 UNITED 11IATER IDAHO CROSS CONNECTION CONTROL PROGRAM PO 8OX190420 BOISE, ID, 83719 TEt 208-362-7304 WWW. UNITEDWATER. COM\I DAHO\BACKFLOW Kelly Rowles 10941 W. Mohawk Pl. Boise, Idaho 83709 April 21, 2015 Request No. 51 Attachment 2 Page 7 of 8 UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Dear Mr. Rowles, It has been determined by United Water Idaho that your property at 10941 W. Mohawk Pl. is required to have irrigatlon backflow protectlon orthe plumbing fixture forthe backflow assembly removed. This is required to protect the public drinking water supply from contamination from potential backflow. You are requlred to lnstall a Reduced Pressure Backflow Assembly behind the meter box on your slde of the water service line. With the assembly lnstalled, it will be your responsibility to have a state licensed Backflow Tester perform an inltlal test on the assembly and send the result to United Water ldaho. Annual testing will be required following the initial test. The second optlon ls to dlg up and remove the sprinkler main valve, draln valve and standpipe for the backflow assembly from the domestic water line. On 8/18/2014,8127/14, and 9/L5/14 our Cross Connection Control Specialist, Stacy Stuart, contacted you wlth a door hanger, by phone or ln person maklng you aware of this requlrement. Unlted Water Idaho's regulatory authority for enforcement of its Cross Connection Control Program fall under the Idaho Rules for Public Drinking Water (IDAPA) 58.01,08 administered by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho Public Utllitles Commission (IPUC) Rules and Regulatlons. Please have the backflow assembly installed and tested or the plumblng fixture removed by 5/4115, Fallure to comply with this notice wlll result in denial or termination of water service to your property. Please contact Stacy Stuart at 362-7383 or myself at362-73a2 with any questions. Yours sincerely, UNITED T"dATER DENNIS FICKES PROGMM ADMINISTMTOR CROSS CONNECTION CONTROL PROGRAM BOISE, ID, 83719 Page 1 United Water ldaho Case UWI-W-15-01 Request No. 5 l Attachment 2 Page 8 of I UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGRAM PO BOX190420 BOISE, ID, 83719 TEL 208-362-7304 WWW, UNITED WATER.COM/IDAHO/BACKFLOW Kim Sanderson Perry Law, PC 2627 W Idaho St Boise, Id 83702 April, Sth 2015 UNITED WATER IDAHO CROSS GONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Dear Klm, It has been determlned by Unlted Water Idaho that an approved backflow assembly ls requlred at your servlce locatlon, Thls Notice of Determlnatlon is meant to Inform you of state requirements to install, malntain, and annually test your requlred backflow assembly (IDAPA 58.01. 08. 552. 05). Detprr*,inatiqn :Q3lltirements fcr vgur prem ise; 2627 W Idaho St. Boise, Id. Instali Double Check Valve Backflow Assembly (Approved by USC FCCCHR) To be installed immediately after the domestic water line enters the premise, but prior to any sub-premise point of service connections,.. Ongoing Test Requirements: Annual lnspected and testing by a state licensed tester Failure to comply with thls notlce wlll result in denlal or termination of water service to your property. Yours slncerely, /r4,4/W UNITED WATER. STACY STUART CROSS CONNECTION CONTROL PROGMM PO 8OX190420 BOISE, ID, 83719 TEL 208-362-7304 WWW. U NITEDWATER.COM/IDAH O/BACKFLOW Premise Servlce Location : Determination: Required Assembly Type: Location for Installatlon : Page 1 United Water ldaho Case UW-W-15-01 Request No. 51 Attachment 3 Page 'l of 1 EMPLOYEE DATE CUSTOMER NAME ADDRESS A representative from United Water Idaho visited your propefty today to look at your lawn sprinkler system. We found one or more of the following problems: Improper or no backflow assembly , installed. Backflow assembly not tested. Sprinkler system back feeding the pressure irrigation system. Sprinkler system connection in the meter box. n Sprinkler system is leaking. tr other Please contact our office immediately to schedule an appointment UNITED WATER IDAHO CROSS CONNECTION CONTROL PROGMM PO BOX190420 BOISE, ID, 83719 TEL 208-352-7304 WWW. U NITEDWATER.COM/IDAHO/BACKFLOW UNITED WATER IDAHO INC.. cAsE uw.w-l$ol SECOND PRODUGTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson EIQUE9LN@: Please provide the results of the inspections program according to: (1) pressure zone orneighborhood; (2) number of facilities inspected; (3) number of prohibited cross-connection devices found; (4) number of tested cross-connection assemblies; and (5) number of cross-connection assemblies with failed tests. RESPONSE NO.52: Please see the file 'CrossConn_by_Pzone.xlsx' for full details. Below is a summary of required devices by pressure zone, 36th Barber Bogart Boulder Central First Columbia WTP Deer Path East First Bench East Go! ren East Main El Pelar Floating Feather Harris Ranch Hidden Valley Hulls Gulch lsland Woods Maple Hills Pasadena Scenic Cove Second Bench Shaw Mountain South County Spunring Toluka Upper Arrowhead West First West Gowen West Main 18 72 1 L9L2 4 1 29 t2 1, 85 3 7 t7 1 27 1 4 3 2 t 5 13 1 t 13 1 305 1 1 4 13 5 3 UNITED WATER IDAHO INC. CASE UW!-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 53: Please explain whether the service or main line's meters have the ability to detect flow directions, including reverse flow. RESPONSE NO. 53: All service and main line meters have the ability to demonstrate flow direction, including reversal of flow. Essentially, meter dials roll ahead when water flows in a forward direction, and roll backward in the event of a flow reversal. Newer automated meter infrastructure (AMl) capable meters offer additional features such as; 'reversal of flow' indicator prompts, frequency of reversal events, and volumetric measurement of unique events. The Company's current meter reading process includes dial comparison of previous and current dial reading to identify flow reversals event for field review. Adoption of the current automated meter infrastructure (AMl) standard will make alerts and response to such events timelier by replacing bi-monthly reading visits with multiple automated daily reports. UNITED WATER IDAHO !NC. GASE UWr-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 54: Please explain whether the Company has detected reverse flow from a customer's system (i.e., back in to the Company's system). lf so, please provide information on how often this situation has been detected since 2012, the customer outreach and correspondence used by the Company, and the amount of time it took the Company to address the risks of detected, active cross-connections. EESElISEllo.s+: Yes, the Company has detected reverse flow from a customer's system back in to the Company's system. Since 2012, the company has observed one such occurrence in the Hobble Creek Subdivision. Standard meter reading procedures found that a water meter at a vacant residence indicated negative consumption (reversal of flow). Follow up on this discovery found that an improper backflow assembly had been installed at the home interconnected with a pressurized alternate irrigation system. The backflow assembly had not been inspected as required by state law. The company was contacted separately by Central District Health authorities regarding multiple cases of localized stomach illness in the same area. The ldaho Department of Environmental Quality was notified, and water samples were taken before the system was flushed. Approximately 383 residences were provided with a hand delivered notice explaining what had happened and steps taken by the Company. A contact number was provided for further questions. Following confirmation of clean water samples for earlier testing, a second customer notice was prepared and hand delivered to customer's residences. Media outlets were updated. (Please See Files 'Request 54 - Hobble Creek Notice 1.pdf and 'Request 54 - Hobble Creek Notice 2.pdf' as reference for outreach correspondence) The company's response to this event lasted a total of 10 days. This does not include the unknown period of possibly repeated flow reversal that may have occurred between bi-monthly meter reading visits. United Water ldaho Case UW-W-15-01 Request No. 54 Attachment 1 Page 1 of2 IMPORTANT CUSTOMER NOTICE FROM UNITED WATER IDAHO Potentia! backflow incident in the Hobble Creek Subdivision June 4,2012 What happened? On Friday, May 25th, through our standard meter reading procedures, United Water ldaho discovered that a water meter at a vacant residence at Plumbcreek & Elmspring, in the Hobble Creek Subdivision, indicated negative consumption since it was last read at the end of March. The next business day, May 29, a service technician inspected the meter and verified the reverse flow. The technician immediately shut off water to the residence, and noted the presence of a backflow prevention device, which was inspected by our Cross-Connection Specialist the next day, May 30. The Cross- Connection Specialist determined that an improper backflow device had been installed at the home, and the unit had not been inspected as required by state law. An untested or improperly installed backflow device has the potential to allow non- potable water to flow into the water distribution system. ln such an event, there is the potential for contaminated water from one location to make its way into the plumbing of other homes in the vicinity. On Friday June 1't, a number of free chlorine residual tests were conducted on samples taken from the water mains in the vicinity of the vacant home. Free chlorine residuals indicate the presence of chlorine, which is used as a disinfectant in the drinking water to protect against harmful bacteria. The results ranged from 0.7-1.0 ppm (parts per million), well in excess of the federal drinking water standard of 0.2 ppm. Today, June 4, six more chlorine residual tests were conducted, and those results again fell within 0.8-1.0 ppm. ln addition, six coliform bacteria samples were taken, and we anticipate test results by Tuesday, June 5. Our crews have also flushed water mains in the area. (over) United Water ldaho Case UW-W-15-01 Request No. 54 Attachment 1 Page 2 ol 2 What should ! do? o United Water ldaho and the ldaho Department of Environmental Quality recommend that you turn up your water heater to the highest temperature possible for several hours and then flush the water heater. Remember to return your water heater to its previous seff,ng after flushing.o You should also flush water softeners, ice makers or any other appliances hooked to your home's water system.o lf there are any filters installed in these appliances or devices, we recommend replacing the filters as well. What is being done? As a result of the free chlorine residuals and flushing in the area, we currently believe your water is safe to drink. United Water ldaho will continue to monitor the affected area and update you as events warrant. For more information, please contact United Water ldaho at362-7328. This notice is being sent to you by United Water ldaho. State Water System lD#: 4010016. Date distributed:614112. United Water ldaho Case UW-W-15-01 Request No. 54 Attachment 2 Page 1 of 1 IMPORTANT CUSTOMER NOTICE FROM UNITED WATER IDAHO Hobble Creek Subdivision Water Update June 5,2012 Dear United Water ldaho Customer: As you know, we believe a backflow event occurred in the Hobble Creek Subdivision, originating at a vacant home at Plumcreek and W. Elmspring. The event was the result of an improper and untested backflow assembly. The purpose of this notice is to update you on the latest information. We have received the test results from the six coliform bacteria samples taken in the water distribution system in Hobble Creek on Monday, June 4. We are pleased to inform you that every sample came back clean, with no evidence of harmful bacteria in the water. These test results confirm that your water is safe to use for all purposes. lf you are still concerned about possible residual effects of any non-potable water in your home, we suggest you take the following steps: o United Water ldaho and the ldaho Department of Environmental Quality recommend that you turn up your water heater to the highest temperature possible for several hours and then flush the water heater. Remember to return your water heater to its previous seffrng after flushing.. You should also flush water softeners, ice makers or any other appliances hooked to your home's water system.. lf there are any filters installed in these appliances or devices, we recommend replacing the filters as well. This event is a reminder to get your home's backflow prevention device tested annually. State-certified testers can be found in the phone book under "Backflow." For backflow information visit www.unitedwater.com/idaho/backflow. lf you have any questions, please contact United Water ldaho a|362-7304. This notice is being sent to you by United Water ldaho. State Water System lD#:4010016. Date distributed: 6/5/12. UNITED WATER IDAHO INC. CASE UW|-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 55: Testimony submitted in Thompson's Dl, page 5, lines 12 - 16 describes a Company- proposed clarification for Rule 15 that "provides the Company with authority to discontinue service without prior notice when a dangerous condition is present." Please explain the following: 'a. Rule 15 states that "ln the event a backflow prevention device is required, it shall be installed, maintained and tested at the customer's expense." Please explain whether the current IDEQ rules require "backflow prevention devices" or "backflow prevention assemblies," and explain under what circumstances each (i.e., device vs. assembly) might be required. b. Has the Company located backflow prevention devices or assemblies that are not authorized? lf so, are these owned by the Company or by customers? And, has the Company obtained testing data, including water main water quality data, confirming that a cross-connection of contaminated water has occurred? lf so, please provide the water quality test results and additional details of the situation. c. Has the Company issued any correspondence to customer-owners of un- authorized backflow prevention devices or backflow prevention assemblies? lf so, please provide example copies. d. Has the Company developed or prepared any correspondence of other written materials to provide to customer-owners of un-authorized backflow prevention devices or assemblies? lf yes, please provide copies. Page 1 of3 UNITED WATER IDAHO INC. CASE UWI-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF e. Has the Company entered into compliance schedules with customers to repair or replace backflow prevention devices or assemblies that are not authorized? lf so, how are the compliance schedules developed and who, within the Company, authorizes them? f. Under normal water main pressure conditions, is there an immediate danger of water main contamination due to an un-authorized backflow prevention device or assembly? Under what conditions might an un-authorized backflow prevention device or assembly cause an immediate danger to water main contamination? How frequently do these situations occur? Please provide the dates, durations, pressure zone locations, and water quality test data that d emonstrate the occurrence of water-mai n cross-con nections contam ination. RESPONSE NO. 55: The terms "backflow prevention device" and "backflow prevention assembly" are used interchangeably to describe a mechanical valve assembly (or air gap) designed to limit the potential for flow reversal in a hydraulic fluid system. Current IDEQ rules for public water system (http://adminrules.idaho,qov/rules/currenU5S/0108.pdf , 543 and 552) outline facility and design standards for cross connection control. These standards include 'list of approved assemblies' from the referenced standards body USC Foundation. Yes, the Company has located unauthorized backflow prevention assemblies. Please see the Company response to Request No. 54 describing the discovery of an improper assembly in the Hobble Creek subdivision. This includes details on the results of water quality testing during this event. Yes, the Company has issued correspondence to customer-owners of un-authorized backflow prevention assemblies. Please see the Company response to Request No. 52 detailing all backflow field determinations since April2014. Page 2 of 3 UNITED WATER IDAHO INC. CASE UWI-W-15-01 SECOND PRODUGTION REQUEST OF THE COMMISSION STAFF Yes, the Company has prepared correspondence to provide to customer-owners of un- authorized backflow prevention devices or assemblies. Please see the Company response to Request No. 51 for examples of correspondence. Yes, the Company has entered into compliance schedules with customers to repair or replace unauthorized backflow prevention assemblies. Please see the Company response to Requests No. 51 and 52 detailing field agreements for correction, and formal letters of determinations 2013-2014. Under normal water main pressure conditions, the immediate danger of contamination due to a cross connection hazard always exists. This would include hazards such as un- authorized backflow prevention assemblies, along with other unprotected cross connection hazards. The Company response to Request No. 54 describing its discovery of an improper assembly in the Hobble Creek subdivision is an excellent example of conditions where an un-authorized backflow prevention assembly caused immediate danger public health. This includes details of that response include results from follow water quality testing during this event. Page 3 of 3 UNITED WATER IDAHO INC. GASE UW!-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Marshall Thompson REQUEST NO. 56: Has the Company conducted any surveys or assessments to determine how many systems lack required cross-connection equipment? lf not, why not? RESPONSE NO. 56: Yes, the Company has conducted field surveys to determine if systems in various parts of the water system lack required cross-connection equipment. UNITED WATER IDAHO INL. GASE UWI-W-I5-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Roger Greaves REQUEST NO. 57: Has the Company conducted any surveys or assessments to determine how many cross-connection devices lack necessary testing? lf not, why not? RESPONSE NO. 57: Yes, the Company has conducted surveys and assessments to determine how many cross-con nection d evices lack necessary testi ng. UNITED WATER IDAHO INC. CASE UW!-W-15-01 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Roger Greaves REQUEST NO. 58: Please provide the make, model, and price of Radio Frequency Meter (RFM) and Automated Meter lnfrastructure (AMl) installed by the Company for each pressure zone, including how many of each type have been installed. RESPONSE NO. 58: The Company has various radio frequency meter r"r,iing endpoints in the system configured for Automated Meter Reading (AMR), also known as "walk or drive by reading". ITRON 60W and 100W Radio Frequencv Endpoints Average Price $70 per Endpoint Please see the attached file 'Request 58 - RF Endpoints by Pressure Zone.xlsx' for a count of ltron radio endpoints by pressure zone. The Company recently adopted a new standard for radio based meter reading without driven collectors. lnstallation of components for this Automated Meter lnfrastructure (AMl) system are underway in 2015. The system consists of two main components: Radio Frequency Endpoints associated with water meters, and stationary tower- mounted network collectors placed around the certificated area. Network collectors will be installed this summer, followed by the first radio endpoints in the fall of 2015. Cost of these system components are detailed here. Sensus SmartPoint Module (520M) Radio Frequencv Endooint for Sinole Meter Settinq Average Price $74.36 per Endpoint Sensus SmartPoint Module (520M2) Radio Frequencv Endpoint for Dual Meter Settino Average Price $88.14 per Endpoint Sensus M400 Radio Frequencv Network Collectors Each stationary collector has a unit cost of $18,000 A total of ten facility mounted M400 collectors will be needed for system meter reading. United Water ldaho Case No. UWI-W-OI Request No. 58-Attachment Pressure Zone Radio Endpoint iount 36th 3 Aldape 27 Andy's Gulch 1 Avimor 1 21 Avimor 3 79 Barber 442 BIF tL2 Bitterbrush 2 Boeart 89 Bogus 25 Boulder 74 Broken Horn 7 Central First 1,7t7 Central Park 10 Chardie 1 Chuckar Butte 1 75 Chuckar Butte 2 1 Clairmont 11 Columbia WTP 101 Crestline 56 Curling 1 Deer Path 36 East First Bench 430 East Gowen 79 East Main 1,257 El Pelar 78 Eyrie 13 Federal 20 Floatins Feather 185 Pressure Zone Radio Endpoint Count Harris Ranch 281 Hidden Sprinss 2 Hidden Valley 35 Hiehland View 30 Hillsboro East 2 Hillsboro West L7 Holcomb 70 Horizon 77 Hulls Gulch 3 lsland Woods 777 Keldoon 1 Lake Forest 2 Lower Arrowhead 5 Lower Boulder Heiehts 72 Lower Braemere 45 Lower Danmor 26 Lower Ginzel 27 Lower Quail 3 Maple Hills 746 Mesa 16 Micron 35 Middle Arrowhead 2 Middle Ginzel 7 Middle Quail 4 Montclair 11 Morning Side 2 Nativa Terra 8 North Mountain 19 Old Pen Lower 1 0regon Trail 60 Pressure Zone Radio Endpoint 3ount )utlook 1 )asadena 18 )ierce 7 )romontory Ridt 20 Ra nch 1 Rideeline 3 Roser Heiehts 8 Scenic Cove 8 Second Bench 26s Shaw Mountain 9 Simplot 16 Skylark 7 South County t,729 Spurwing L75 Surprise Valley 577 Ten Mile Ridge 6 Toluka 11 Iwilight 8 Upper Arrowhea 57 Upper Boulder 3 Upper Boulder F]5 Upper Braemere 8 Uooer Danmor 6 Uooer Ginzel 1 Upper Quail 2 Upper Ridge 1 West First 2,5L8 West Gowen 227 West Main 574