20150828Staff 131-148 to UWI.pdf

DONALD L. HOWELL, II
DAPHNE HUANG
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-03 121334-03 t8
IDAHO BAR NOS, 336618370
Street Address for Express Mail:
472 W, WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
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.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. UWI-W-15-01
SEVENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
UNITED WATER IDAHO INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Donald L. Howell and Daphne Huang, Deputy Attorneys General, request that United
Water provide the following documents and information as soon as possible, or no later than
FRTDAY, SEPTEMBER 18, 2015.
This Production Request (PR) is to be considered as continuing, and United 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, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
SEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO AUGUST 28,2015
In addition to the wriffen copies provided as response to the requests, please
Excel and electronic files on CD with formulas activated.
REQUEST NO. 131: In reference to the Company's response to PR #39, please provide
a PDF copy of the Company's Pressure ZoneMap that can be enlarged using an Acrobat Reader
or hard copy at a scale that can be read, and with enough detail so that the zone boundaries can
be deciphered (See Company PR #39, Roger Greaves). Please clearly illustrate areas that contain
alternative, high pressure, irrigation or other non-potable water sources.
REQUEST NO. 132: Please provide a copy of the 2015 and 2016 Capital Investment
Plan (See Company PR #40, Roger Greaves).
REQUEST NO. 133: Please provide a copy of the Company's current Idaho Master
Plan.
REQUEST NO. 134: In reference to the Company's response to PR #47,the "United
Water Idaho Cross Connection Control Program" (July 2013), page 15, is the updated data from
customer cross connection testing added to the customer account record? If not, is the customer
testing data made available to the Customer Service representatives for the purpose of
responding to customer inquiries and complaints? If not, please make it available.
REQUEST NO. 135: In reference to the Company's response to PR #49, please explain
how the Company is notified when an existing residential customer installs a cross connection
assembly or device. Is the notification process the same regardless of whether or not the
customer is located within a municipality?
REQUEST NO. 136: In reference to the Company's response to PR #49, does the
Certificate of Occupancy require the Company to inspect and sign off on cross connections?
REQUEST NO. 137: In reference to the Application, Exhibit 24, Sheets 13-14,
paragraph 14, the Company proposes "lnstalled assemblies shall appear on the Idaho State
SEVENTH PRODUCTION REQUEST
TO LTNITED WATER IDAHO AUGUST 28,2015
Department of Environmental Quality's list of approved backflow prevention assemblies and be
inspected by the Company prior to initiating service." Please clarify if the Company is seeking
authority to inspect the assembly prior to installation, or to inspect the assemblies following
installation for new connections.
REQUEST NO. 138: In reference to the Company's response to PR #50, please provide
the job titles, Standard Occupational Codes, specific support capacity, any qualifications or
certifications obtained to support the Cross Connection Control Program, and the percentage of
time (i.e., full time equivalency) the 5 employees dedicated to the Company's Cross Control
Program, during 2013 and 2014. Please provide all direct costs to this program, such as direct
mailings. Please provide all indirect costs, such as overhead management costs and salaries.
REQUEST NO. 139: In reference to the Company's response to PR #51, please explain
how the Company is notified when an existing customer, of any type, has an existing cross
connection assembly or device tested. How does the Company confirm that the person
performing the testing has adequate certification and/or expertise?
REQUEST NO. 140: In reference to the Company's response to PR #51, please provide
examples of notices sent to customers regarding backflow assembly testing, including'Notice to
Test Your Irrigation/Fire Backflow Assembly."
REQUEST NO. 141: In reference to the Company's responses to PRs #52,#56, and#57
please provide supporting data base(s), split into customer categories (i.e., commercial,
industrial, residential) for the following summary information:
o the total number of customers with known cross connection devices for 2012,2013,
and20l4l'
the total number of cross connection devices tested during 2012,2013, and2014;
the total number and percentage of customers for pressure zones that have been
surveyed, inspected, or assessed, grouped by pressure zone; and
SEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO AUGUST 28,2015
o the specific time line and estimated completion date for when all pressure zones will
be surveyed, along with the frequency of surveys going forward for each of the
pressure zones.
REQUEST NO. 142: In reference to the Company's response to PR #53, please explain
how often main or service connection meters were used to detect reverse flow during 2013 and
2014. Does the Company intend to utilize any meter data in the future to detect possible reverse
flow events?
REQUEST NO. 143: In reference to the Company's response to PR #54, does the
Company turn off service when a customer has terminated service and there is no pending tum-
on request? Does the presence of a backflow prevention device affect the Company's decision to
turn offservices for vacant properties?
REQUEST NO. 144: In reference to the Company's response to PR #55, please provide
the average time between initial notification by the Company of non-compliance, and final
customer compliance with the Company's Cross Connection Control Program for systems with
year-round use for the following:
o testing of backflow assemblies and devices;
. a lack of backflow protection; and
o an improper backflow protection assembly or device.
REQUEST NO. 145: In reference to the Company's response to PR #55, please provide
the average time between initial notification by the Company of non-compliance and final
customer compliance with the Company's Cross Connection Control Program for systems with
seasonal use for the following:
o testing of backflow assemblies and devices;
. a lack of backflow protection; and
. an improper backflow protection assembly or device.
SEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO AUGUST 28,2015
REQUEST NO. 146: In reference to the Company's responses to PRs #56 and#57, are
the frequency of planned surveys correlated with any identified risks, Company-identified
priorities, or deployment of any AMI equipment?
REQUEST NO. 147: In reference to the Company's response to PR #51, please provide
copies of the Company's annual and long-term Cross Connection Control Program work plans.
REQUEST NO. 148: In the Cross Connection Program document, page 18, it states:
"Customers can avoid termination by providing United Water with evidence of annual testing, or
by demonstrating to United Water Idaho's Cross Connection Control Specialist(s) that
permanent physical separation exists between potable water service and related cross connection
hazards." In United Water Idaho's tariff, Sheet No. 14, it states: "16. When the premises served
by the Company is also served in any manner from another supply of water, public or private, the
customer must install the appropriate backflow prevention device or maintain a physical
separation between the two systems at all times. The type of device or separation and the
installation of the device or separation shall be determined by the Company in accordance with
its Cross Connection Control Program as approved by the State Health Department."
Please provide examples of and specifications for a "permanent physical separation."
What is the rationale for this requirement?
DATED at Boise, Idaho, tt'ris Elu6ay of August 2015.
Technical Staff: Johanna Bell (131-133, 135-139, l4l-147)
Chris Hecht (134,140)
Jolene Bossard (148)
i : umisc :prodreq/uwi I 5. I dhdjhrpsjbmechjbojtphtcmmac prod req 7 to UWI
SEVENTH PRODUCTION REQUEST
TO UNITED WATER IDAHO
II, II
Deputy Attorney General
AUGUST 28,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28th DAY OF AUGUST 2015,
SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO UNITED WATER IDAHO, IN CASE NO. UWI-W-15-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE TD 83702
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N 17TH STREET
BOISE tD 837092
E-MAIL: [e-mail]
E-MAIL ONLY: [e-mail]
gre e. wyatt@unitedwater. com
i [e-mail]
gary. prettyman@unitedwater. com
walton. hill@ unitedwater. com
debra.visco nti @ u nitedwater.com
[e-mail]
KEVIN H DOHERTY
LINITED WATER MANAGEMENT
AND SERVICES CO
2OO OLD HOOK ROAD
HARRINGTON PARK NJ 07640
E-MAIL: [e-mail]
heather@mcdevitt-miller. com
CERTIFICATE OF SERVICE