20150921UWI to Staff 134-137,139-141,143-148.pdf

McDevitt & Miller rrPLawvem i,:lil .q[i- ? I Fl,,l !; og
(208) 343-2s00 *$X:il"1ffi::5r?fi*
, ,ir-i','i:: ,,i, ,,c F:McDe'itt
(208) 33G6912 (Farr) Boiee,Idaho 83702 DeanJ. floe) Millet
Celeste Ii Millet
Septembet 27,2075
Via l{aad Delivety
JeanJewell, Seceary
I&ho Public Utilities Commission
472W. Washington St.
Boise,Idaho 83720
Re: UWI-W-15-01
Deat Ms.Jewell:
Eoclosed fot filing, please find an original and three (3) copies of United $Vater Idaho's Third
Response to the Commission Staffs Seventh Production Request Nos. 134, 135,736,737,139,740,
147, 743, 144, 145, 746, 747 and 148.
Kindly returfl a file stamped copy to me.
Very Ttuly Yours,
McDevitt & MilletLLP
UAw-
DeanJ. Millet
DJM/M
Cq United Watet Idaho, Inc.
ORICINAL
Dean J. Miller (lSB No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 25U-83701
Boise, lD 83702
Tel: [phone]
Fax [phone]
ioe@mcdevitt-m iller. com
::i :',':-l t';1 l:[9
r.,:-ill".-,, , ': i- -l, ' :"'';"-'
Attomey for United Water ldaho, lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
lN THE MATTER OF THE APPLICATION I Case No. UWI-W-15-01
OF UNITED WATER IDAHO INC. FOR
AUTHORITY TO INCREASE ITS RATES I UNITED WATER IDAHO INC.'S
AND CT{ARGES FOR WATER SERVICE I THIRD RESPONSE TO SEVENTH
IN THE STATE OF IDAHO PRODUCTION REQUEST OF THE
commtssroN STAFF
United Water ldaho lnc., ("United Wate/') by and through its undersigned
aftorneys, hereby submits its Third Response to the Commission Staffs Seventh
Production Request Nos. 134, 135, 136, 137, 139, 14O,141,143,144,145,146,147
and 148.
DATED this Lr,day of September,2015.
UNITED WATER IDAHO INC.'S THIRD RESPONSE TO SEVENTH PRODUGTION REQUEST OF THE
coirrrsstoN STAFF - l
UNITED WATER IDAHO INC.
Deah 3. Miller (lSB No. 1968)
Attomey for United Water ldaho, lnc.
CERTIFICATE OF SERVICE
I hereby certify that on tn" 3\tt"y of September 2015,1 caused to be served,
via the method(s) indicated below, true and correct copies of the foregoing document,
upon:
Jean Jewell, Secretary Hand Delivered #
ldaho Public Utilities iommission U.S. Mail 'j
472 West Washington Street Fax .-i
P.O. Box 83720 Fed. Express ,-i
Boise, lD 83720-0074 Email d
iiewell@puc. state. id. us
Hand Delivered
Donald L. Howe!!, ll U.S. Mail
Daphne Huang Fax
Deputy Attorney General Fed. Express
ldaho Public Utilities Commission Email
P.O. Box 83720
Boise, Idaho 83720-0074
don. howell@puc. idaho.qov
daphne. huanq@puc. idaho.qov
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, lD 83702
[e-mail]
rql
(-a
(J
LI
Hand Delivered ,r
U.S. Mail d
Fax L-i
Fed. Express !iEmail X
BY,;;|\+?S\,Y*$qrl\I ( [-p roo isLMcDevrr & Mruen LLP ' v
UNITED WATER IDAHO INC.'S THIRD RESPONSE TO SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF.2
UNITED WATER IDAHO INC.
CASE UWI-W.15.01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
PrepareriSponsoring Witness: Marshall Thompson
REQUEST NO. 134: In reference to the Company's response to PR #47,the "United
Water ldaho 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? lf
not, please make it available.
RESPONSE NO. 134: Following submittal of a backflow test report, the Company
updates data associated with the customer device record. This record system is
currently separate from the customer billing account record. This data is in the process
of being made available via a GIS interface tool to the Customer Service
Representatives for response to customer inquiries and complaints. The Company
expects this project to be completed by the end of the 2015 calendar year.
UNITED WATER IDAHO INC.
CASE UWI-W-15.01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 135: ln 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. ls the notification process the same regardless of
whether or not the customer is located within a municipality?
RESPONSE NO. 135: There are two main discovery routes for Company notification
when an existing residential customer installs a cross connection assembly or device.
1) Plumbers, backflow companies, and most irrigation contractors will submit an
initial backflow test report certifiTing new cross connection assemblies upon
installation. The same holds true when these contractors replace pre-existing
assemblies due to device failure. The majority of cross connection assemblies in
the Company data record followed this path of notification.
2) The second route is direct observation by Company staff during field
investigations. lt is clear from these efforts that many homeowners have chosen
to install cross connection assemblies using non-standard means (homeowner
self-perfo rmance, u n I icensed irrigation wo rk).
Notification processes are the same regardless of customer location inside or outside a
municipality.
UNITED WATER IDAHO INC.
CASE UWI.W.I5.O1
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 136: ln 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?
RESPONSE NO. 136: Certificates of Occupancy are administered by local plumbing
inspectors in accordance with building code requirements. Final approval on larger
service settings includes observation of initial testing on cross connection assemblies by
a state licensed backflow assembly tester. The Company does not sign-off on either the
initial assembly test or certificates of occupancy.
ln instances where a cross connection assembly may be in question, local plumbing
inspectors routinely contact the Company for inclusion on final commercial system
inspections and assembly test. This provides the Company with the opportunity to alert
the plumbing inspectors of any concerns to public health or system safety to be
addressed prior to certificate approval.
ln any instance where a threat to public health is found to be related to the water service
connection, the Company will isolate and lock-off service to that property (regardless of
a certificate of occupancy approval). The service will remain isolated until the cross
connection hazard is mitigated.
UNITED WATER IDAHO INC.
CASE UWI.W.I5.O1
SEVENTH PRODUGTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 137: ln reference to the Application, Exhibit 2A, Sheets 13-14,
paragraph 14, the Company proposes "lnstalled assemblies shall appear on the ldaho
State 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.
RESPONSE NO. 137: The Company is seeking authority to inspect the assemblies
following installation for new connections. Proper installation and function of a backflow
assembly cannot be observed prior to installation.
UNITED WATER IDAHO INC.
GASE UWI-W-15-01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 139: ln 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?
RESPONSE NO. 139: The Company receives notification when an existing customer,
of any type, has an existing cross connection assembly tested via a standard backflow
testing report (or that reports electronic equivalent). Reports are received from
plumbers, backflow testing companies, and certified irrigation contractors within 15 days
of testing as required by the Company cross connection control program.
The Company confirms that the person performing the testing has adequate certification
and/or expertise by validating their state licensure as a certified Backflow Assembly
Tester against the ldaho Bureau of Occupational Licensing (IBOL) certification
database. lflwhen the Company discovers, via annual tester certification audits,
instances of unlicensed testers, they are then reported to IBOL and IDEQ.
UNITED WATER IDAHO INC.
GASE UWI.W-I5-01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/SponsoringWitness: MarshallThompson
REQUEST NO. 140: ln 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 lrrigation/Fire Backflow Assembly."
RESPONSE NO. 140: Please see the included file (#140 - Testing Notice.pdf) as an
example of the customer notice sent for required backflow testing. This file shows an
individual premise assembly test notice to ldaho Military Division.
A large extract of more than four-thousand notices covering multiple residential meter
books has been prepared and can be made available for review at the Company offices.
UNITED WATER IDAHO INC.
CASE UWI.W-15.01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
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:
. the total number of customers with known cross connection devices for 2012,
2013, and2014;
. the total number of cross connection devices tested during 2012,2013, and
2014;
. the total number and percentage of customers for pressure zones that have
been surveyed, inspected, or assessed, grouped by pressure zone; and 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.
RESPONSE NO. 141:
o The total number of known cross connection devices in 2012, 2013, and
2014.
Year Device Gount
2012 21,756
2013 23,789
2014 24,390
. The total number of cross connection devices tested during 2012,2013, and
2014.
Year Test Gount
2012 10,748
2013 11,606
2014 11,250
Page 1 of2
The total number of customers that have been surveyed, inspected, or
assessed, grouped by pressure zone was previously detailed in PR #52.
. With adjustments made for annual meter replacements incorporating
automated alerts for flow reversal and the count of known backflow
assemblies, the company estimates that it will take 8+ years to survey all
pressure zones.
The frequency of surveys going fonrvard for each of the pressure zones will be
dictated by the record of compliance and assessed hazard. Availability of
automated alerts for flow reversal on individual meters has the potential to
tailor future survey efforts toward greater specificity, thereby reducing the
need and frequency for zonal assessment.
Page 2 of 2
UNITED WATER IDAHO ING.
CASE UWI-W-15.01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 143: ln 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 turn-on request? Does the presence of a backflow prevention device affect the
Company's decision to turn off services for vacant properties?
RESPONSE NO. 143: The Company does turn off service when a customer has
terminated service and there is no pending turn-on request.
The Field Service Person attending to this task has discretion to delay the turn-off if they
suspect the property or home is still occupied. This can occur when a departing
landowner incorrectly requests a turn-off when a service transfer should have been
requested. ln such instances, the Field Service Person will contact the occupant if
possible, or leave a door tag instructing them to call the office and have the service put
in their name. lf the customer does not respond within 48 hours, a Field Service Person
will return to the property and shut the service off.
The presences of a backflow assembly does not affect the Company's decision to turn
off services to vacant properties unless an improper backflow assembly is discovered,
or the property is determined to have an unprotected cross connection with a non-
potable water source that could pose a risk to public health.
UNITED WATER IDAHO INC.
CASE UWI-W-15.01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 144: ln 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:
testing of backflow assemblies and devices;
a lack of backflow protection; and an improper backflow protection assembly
or device.
RESPONSE NO. 144:
Year-round premise isolation for backflow protection is associated with a subset of
customer profiles; commercial, public authority, and fire services over two-inches and
larger in diameter (>2in).
The Company provides annual notification on the status and need for continued testing
for all registered backflow assemblies in its database. To date, no efforts beyond
notification have been necessary to ensure compliance with this group's regular testing
requirements. Therefore, the average time between initial notification by the Company
of non-compliance, and final customer compliance has not been measured.
The Company has no record of a year-round assembly owner lacking protection, or
showing evidence of improper assembly installation. lt is the opinion of the Company
that this group's record of compliance is a byproduct of greater attention to plumbing
and fire code requirements for customers of this type.
a
a
UNITED WATER IDAHO INC.
CASE UWI-W-I5-01
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 145: ln 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:
testing of backflow assemblies and devices;
a lack of backflow protection; and
an improper backflow protection assembly or device.
RESPONSE NO. 145: Seasonal need for backflow protection is primarily associated with
customer profiles for residential or irrigation service. The same customer profiles are found to be
the least compliant with standards for backflow protection. Residential and irrigation service
connections are a primary focus for cross connection field surveys.
The Company provides annual notification on the status and need for continued testing for all
registered backflow assemblies in its database. To date, no efforts beyond annual notification
have been taken to ensure compliance with regular testing requirements. The average time
between the initial notice of testing non-compliance and customer compliance has not been
measured.
Field survey results previously summarized in PR #52 are the only reliable reference for a lack
of backflow protection or improper installation. The referenced detailfile
'CrossConn_by_Pzone.xlsx' from PR# 52 is representative of the timeline from notification to
compliance.
The file shows surveys conducted in the time period from April 2014 to May 2015 had an
average time of 28 days from the date of initial notification of non-compliance to the Company's
first follow up contact. The average time from initial notification to final resolution was 96 days.
a
a
a
UNITED WATER IDAHO INC.
CASE UWI.W.15.O1
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 146: ln 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?
RESPONSE NO. 146: Residential and irrigation service connections are the primary
focus of Company cross connection field surveys.
Particular focus is placed on the subset of residential customers with access to non-
potable irrigation water. This service grouping has been the entry point for system
contamination in two past events, each of which resulting in localized public illness
around the point of entry. Company survey results have shown that the same groups of
customers are often unaware of this risk, and non-compliant with backflow protection
and testing standards.
Wide-spread access to non-potable irrigation water from regional canal systems and
private wells in all areas of the system increases the likelihood of identifying a
hazardous cross connection in any part of the Company service territory.
Cross connection surveys are not specifically planned in conjunction with planned
deployment of any AMI equipment. However, AMI equipped meters may be installed as
a verification tool on customer service lines where reconnection to a previously isolated
backflow hazard is likely.
UNITED WATER IDAHO INC.
CASE UWI.W.I5.O1
SEVENTH PRODUGTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
REQUEST NO. 147: ln 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.
RESPONSE NO. 147: The Company does not have a documented long-term cross
connection work plan for field surveys. lt is the Company's intention to assess all water
service connections for cross connection hazard and mitigate associated risks to public
health.
lf work continues at the present rate, in parallel with meter replacement efforts
incorporating AMI and automated alerts for flow reversal, the Company estimates that it
will take 8+ years to complete this long-term work plan.
UNITED WATER IDAHO INC.
CASE UWI.W.15.O1
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Marshall Thompson
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 ldaho's Cross Connection Control
Specialist(s) that permanent physical separation exists between potable water service
and related cross connection hazards." ln United Water ldaho'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?
RESPONSE NO. 148: Please see the included PDF file "PR148 - Cross Conn
Examples.pdf in response to this request.
Permanent physical separation implies that the pathway for a potential cross connection
has been physically removed to lasting effect. This could be as simple as the removal of
a bridged hose fitting between an outside faucet and an irrigation box, or the excavation
of underground piping between an irrigation system and Company water main or
service line.
In new construction, mitigation of any potential cross connection risk occurs during the
design review and inspection process. The section referenced above refers to hazards
Page 1 of2
that are discovered after the fact, as during field surveys on older infrastructure where
plumbing and mechanical alterations have been done without code approval.
lf it is determined by Company staff that a cross connection hazard exists, the customer
has one of two options. lf possible, they can instal! an appropriate form of backflow
protection between the public water system and the hazard. The alternative is to
eliminate the inter-connection entirely. ln some instances, permanent physical
separation is the least cost option for the customer, and requires no ongoing assembly
testing or maintenance.
Page 2 of 2
Request No. 148 Attachment
Page 1 of5
.United Water ldaho
Case UW-W-15-0'l
oPEl-(I,N(I,
I
(U
hoCao
CL
tnEo
P()oCCoU
ItntnoliU
E
(1,a'=
ot-o-
E
FJ-q-uoE
oo -E#$ o- ,rrlC.=+r kEEx=o- Lu o-
Unlted Water ldaho
' Case UWI-W-15-01
ryj*i,'r -*i
L.ur d
&k,'*
&':;,,,F
il",{jr'
Request No. 148 Attachment
Page 2 of 5
United Water ldaho
Case [JWI-W-15-01
Request No. 148 Altachment
Page 3 of 5
Request No. 148 Attachment
Page 4 of 5
United Water tdaho' Case UW-W-'15-01
Co
*)(ot-((,o-oa
]E.9t/1
.Ca-
PCoc(o
E
o(]-
tlo
o
o-
E
rt,xLU
oosf,t-l{t
E,a-
United Water ldaho
Case UW-W-15-01
Request No. 148 Attachment
Page 5 of 5
-'ir.r.3
{",i.{i'
;'tl,,'r."'?'.si
i,,f!
'-'.'.""
,li
,..
t'l
,i}:l!:,1,,."{,i:: -i
,:?':i
'+!s