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1 Control Number : Item Number : 171 Addendum StartPage : 0
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3 SOAH DOCKET NO PUC DOCKET NO WS PETITION OF NORTH AUSTIN MUNICIPAL UTILITY DISTRICT NO. 1, NORTHTOWN MUNICIPAL UTILITY DISTRICT, TRAVIS COUNTY WATER CONTROL AND IMPROVEMENT DISTRICT NO. 10 AND WELLS BRANCH MUNICIPAL UTILITY DISTRICT FROM THE RATEMAKING ACTIONS OF THE CITY OF AUSTIN AND REQUEST FOR INTERIM RATES IN WILLIAMSON AND TRAVIS COUNTIES BEFORE THE STATE OFFICE ADMINISTRATIVE HEARINGS SOAH DOCKET NO WS PUC DOCKET NO PETITION OF NORTH AUSTIN MUNICIPAL UTILITY DISTRICT NO. 1, NORTHTOWN MUNICIPAL UTILITY DISTRICT, AND WELLS BRANCH MUNICIPAL UTILITY DISTRICT FROM THE RATEMAKING ACTIONS OF THE CITY OF AUSTIN AND REQUEST FOR INTERIM RATES IN WILLIAMSON AND TRAVIS COUNTIES BEFORE THE STATE OFFICE OF ADMINISTRATIVE HEARINGS TRAVIS COUNTY WATER CONTROL AND IMPROVEMENT DISTRICT NO. 10'S THIRD SUPPLEMENTAL RESPONSE TO CITY OF AUSTIN'S THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO: City of Austin, by and through its attorneys of record, Stephen P. Webb and Gwendolyn Hill Webb, Webb & Webb, 712 Southwest Tower, 211 East 7th Street, Austin, Texas COMES NOW, Travis County Water Control and Improvement District No. 10 ("Travis WCID," "Petitioner" or "District"), in the above-styled and numbered cause, and serves this, its Third Supplemental Response to the City of Austin's Third Request for Production of Documents. k-(l
4 Respectfully submitted, Randall B. Wilburn, Attorney at Law State Bar No South IH 35, Suite 150 Austin, Texas Telephone: (512) Fax: (512) John Carlton State Bar No The Carlton Law Firm, P.L.L.C Bee Cave Road, Suite 200 Austin, Texas Telephone: (512) Fax: (512) By: JOHN J. CARLTON COUNSEL FOR PETITIONER CERTIFICATE OF SERVICE I certify that I served a true and correct copy of the foregoing document on all parties of record in this proceeding on this 5th day of December, 2014 via hand delivery, facsimile, electronic mail, overnight mail, U.S. mail and/or certified mail. ^ JOHN J. CARLTON 2
5 PRODUCTION REQUESTS The following requests pertain to the written prefiled testimony of Thomas Arndt for Travis County Water Control and Improvement District No Please provide any and all documents that indicate that prior to 2012 the City did not provide the State minimum pressure to the Red Bud Pump Station and that the City was notified of the issue. Objection: Travis WCID objects to this request on the grounds that it is unduly burdensome because the information is equally available to the City and the documents are obtainable by the City from an alternative source. Response: Notwithstanding and without waiving the objections noted above, responsive and non-privileged documents will be produced. 3 3
6 Tom Arndt Subject: FW: WD10 - Incoming PSI to Redbud Pump Station From: Mike Morin <MMorin@crossroadsus.com> Date: Monday, January 9, 2012 at 10:19 AM To: "Jennings, Bart" <Bart.Jennings@austintexas.gov> Cc: "Martinez, Lisa" <Lisa.Marti nez austintexas.gov>, Carla Glass <waterdistrictlo@austin.rr.com>, William Abshire <WAbshire@crossroadsus.com> Subject: RE: WD10 - Incoming PSI to Redbud Pump Station Bart, While I appreciate your help in this matter, it appears to me that the problem has not been entirely corrected. When I pull up the pressure recordings you sent, the pressures appear to average under 45 psi. The comment below states that we can expect pressures at the Red Bud meter to be about 10 psi lower than the recordings. That would still put us under the required 35 psi threshold most of the time. Please let me know if anything can be done to correct this situation. Mike Morin From: Jennings, Bart [mailto: Bart.Jennings(d)austintexas.aov] Sent: Monday, January 09, :30 AM To: Travis County WCID #10()coaspmp4.ci.austin.tx.us; Mike Morin Cc: Martinez, Lisa Lisa is out sick today so I am sending this information. Please read the chain of s below. If you have any questions or concerns, please call me or Lisa. Thanks. Bart From: Jennings, Bart Sent: Saturday, January 07, :56 AM To: Martinez, Lisa Please pass this information to Paul Wakefield and Mike Morin. Thanks. Bart From: English, Jeremy Sent: Friday, January 06, :25 PM P-TC
7 To: Vicent, Francisco; Coronado, Rick; Morabbi, Mehrdad; Pruneda, Jaime Cc: Jennings, Bart; Lutes, Teresa; Dollins, Mark; Wendel, Don; Smith, Joe [WCC7] Subject: RE: WD10 - Incoming PSI to Redbud Pump Station All Attached is pressure recorder data from the hydrant at Redbud & Forest View taken after the valves were opened. It appears fairly stable except for what looks like small spikes from what I assume is WCID #10 pumps turning on and off. Based on map contours I would estimate the pump station pressures are approximately 10psi lower than what we are reading at the hydrant. Jeremy H. English P.E. Austin Water Utility Systems Planning From: Vicent, Francisco Sent: Friday, January 06, :05 AM To: Jennings, Bart; Coronado, Rick; Martinez, Lisa; Burazer, Jane; Lutes, Teresa; Dollins, Mark; Morabbi, Mehrdad; Carrico, Steven; English, Jeremy; Smith, Joe [WCC7]; Musgrove, Judy; Wendel, Don Subject: RE: WD10 - Incoming PSI to Redbud Pump Station All, This week, Wednesday the 4`h, we met at Ullrich WTP and identified a couple of valves located in Vault # 1 that were in the closed position. After we opened them, we noticed an improvement in the discharge pressure. Most certainly that will have an impact in Travis County WCID #10 operation. To be more proactive, we also made an adjustment on the alarm settings. We will continue to closely monitor the MS discharge pressure. Ps: it will be a great idea to set a pressure monitoring device (pressure point) before their station to provide better service. From: Jennings, Bart Sent: Friday, January 06, :38 AM To: Vicent, Francisco; Coronado, Rick; Martinez, Lisa; Burazer, Jane; Lutes, Teresa; Dollins, Mark; Morabbi, Mehrdad; Carrico, Steven; English, Jeremy; Smith, Joe [WCC7]; Musgrove, Judy; Wendel, Don Additional information. Bart From: Mike Morin [maiito: MMorin Ca^crossroadsus.com] Sent: Friday, January 06, :30 AM To: Jennings, Bart ^ ^ _.. I have attached the Travis County WCID #10 report showing specific pressures at the Red Bud pump station. The report also shows the time of day the pressures were recorded. Please let me know if you have an answer as to what is causing the problem. Thank you, P-TC
8 Mike Morin Crossroads Utility Services From: Coronado, Rick Sent: Tuesday, January 03, :34 PM To: Jennings, Bart; Martinez, Lisa Cc: Burazer, Jane; Vicent, Francisco; Lutes, Teresa; Dollins, Mark; Morabbi, Mehrdad; Carrico, Steven; English, Jeremy; Smith, Joe [WCC7]; Musgrove, Judy Bart, This is the first official document that we have received from WCID # 10 on this issue. We have received other means of communication via phone on interruptions in the pumping system at Red Bud. I will forward this information to Planning, WTP, Engineering. As of this morning the discharge pressure at Ullrich WTP was above 35 psi but in the low alarm state. I believe this will take a team approach to get to the root cause of this low pump station suction pressure issue. It may be as simple as a closed valve that we are not aware of or as technical as an undersized line to WCID #10. I will ask Francisco to set up a meeting to address this issue with the team. Rick From: Mike Morin Sent: Tuesday, January 03, :59 AM To: Bart.JenningsC&ci.austin.tx.us Cc: William Abshire; 'Water District 10' Subject: WD10 - Incoming PSI to Redbud Pump Station Bart, I have attached reports from August thru November showing specific dates, times and PSI in numbers. I will send you the December report in the morning. This should hopefully help in pinpointing the problems we are having. Let me know if you need any other information. Thanks, Mike Morin Crossroads Utility Services 2601 Forest Creek Drive Round Rock, TX mmorin@crossroadsus.com P-TC
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10 Tom Arndt Subject: Attachments: FW: WD10 - Incoming PSI to Redbud Pump Station salesdemo@dahill.com_ _ pdf From: Water District 10 [mailto:waterdistrictl0@austin.rr.com] Sent: Monday, December 01, :36 PM To: Tom Arndt From: Mike Morin <MMorin@crossroadsus.com> Date: Friday, January 13, 2012 at 8:23 AM To: "Jennings, Bart" <Bart.Jennings c austintexas.gov> Cc: "Martinez, Lisa" <Lisa.Martinez austintexas.gov>, Carla Glass <waterdistrictlo@austin.rr.com>, William Abshire <WAbshire@crossroadsus.com> Subject: RE: WD10 - Incoming PSI to Redbud Pump Station Ba rt, I have attached a copy of our January report that includes information thru yesterday. It shows that the City has only met their obligation to provide water at 35 psi 2 times out of 12 days checked so far. I do not feel the problem has been solved yet. Mike Morin Crossroads Utility Services Travis County W.C.I.D. #10 From: Mike Morin Sent: Monday, January 09, :20 AM To: 'Jennings, Bart' Cc: Martinez, Lisa; 'Water District 10'; William Abshire Subject: RE: WD10 - Incoming PSI to Redbud Pump Station Bart, While I appreciate your help in this matter, it appears to me that the problem has not been entirely corrected. When I pull up the pressure recordings you sent, the pressures appear to average under 45 psi. The comment below states that we can expect pressures at the Red Bud meter to be about 10 psi lower than the recordings. That would still put us under the required 35 psi threshold most of the time. Please let me know if anything can be done to correct this situation. Mike Morin P-TC
11 From: Jennings, Bart [mailto:bart.jenningsca^austintexas oov] Sent: Monday, January 09, :30 AM To: Travis. County. WCID.#10Ca)coaspmp4 ci austin tx us; Mike Morin Cc: Martinez, Lisa Lisa is out sick today so I am sending this information. Please read the chain of s below. If you have any questions or concerns, please call me or Lisa. Thanks. Bart.., _.,.... From: Jennings, Bart _,... _,.,._,. Sent: Saturday, January 07, :56 AM To: Martinez, Lisa Please pass this information to Paul Wakefield and Mike Morin. Thanks. Bart From: English, Jeremy Sent: Friday, January 06, :25 PM To: Vicent, Francisco; Coronado, Rick; Morabbi, Mehrdad; Pruneda, Jaime Cc: Jennings, Bart; Lutes, Teresa; Dollins, Mark; Wendel, Don; Smith, Joe [WCC7] Subject: RE: WD10 - Incoming PSI to Redbud Pump Station All Attached is pressure recorder data from the hydrant at Redbud & Forest View taken after the valves were opened. It appears fairly stable except for what looks like small spikes from what I assume is WCID #10 pumps turning on and off. Based on map contours I would estimate the pump station pressures are approximately 10psi lower than what we are reading at the hydrant. Jeremy H. English P.E. Austin Water Utility Systems Planning From: Vicent, Francisco Sent: Friday, January 06, :05 AM To: Jennings, Bart; Coronado, Rick; Martinez, Lisa; Burazer, Jane; Lutes, Teresa; Dollins, Mark; Morabbi, Mehrdad; Carrico, Steven; English, Jeremy; Smith, Joe [WCC7]; Musgrove, Judy; Wendel, Don Subject: RE: WD10 - Incoming PSI to Redbud Pump Station AII, This week, Wednesday the 41h, we met at Ullrich WTP and identified a couple of valves located in Vault # 1 that were in the closed position. After we opened them, we noticed an improvement in the discharge pressure. Most certainly that P-TC
12 will have an impact in Travis County WCID #10 operation. To be more proactive, we also made an adjustment on the alarm settings. We will continue to closely monitor the MS discharge pressure. Ps: it will be a great idea to set a pressure monitoring device (pressure point) before their station to provide better service. From: Jennings, Bart Sent: Friday, January 06, :38 AM To: Vicent, Francisco; Coronado, Rick; Martinez, Lisa; Burazer, Jane; Lutes, Teresa; Dollins, Mark; Morabbi, Mehrdad; Carrico, Steven; English, Jeremy; Smith, Joe [WCC7]; Musgrove, Judy; Wendel, Don Additional information. Bart From: Mike Morin [maiito: MMori nca>crossroadsus.coml Sent: Friday, January 06, :30 AM To: Jennings, Bart I have attached the Travis County WCID #10 report showing specific pressures at the Red Bud pump station. The report also shows the time of day the pressures were recorded. Please let me know if you have an answer as to what is causing the problem. Thank you, Mike Morin Crossroads Utility Services From: Coronado, Rick Sent: Tuesday, January 03, :34 PM To: Jennings, Bart; Martinez, Lisa Cc: Burazer, Jane; Vicent, Francisco; Lutes, Teresa; Dollins, Mark; Morabbi, Mehrdad; Carrico, Steven; English, Jeremy; Smith, Joe [WCC7]; Musgrove, Judy Bart, This is the first official document that we have received from WCID #10 on this issue. We have received other means of communication via phone on interruptions in the pumping system at Red Bud. I will forward this information to Planning, WTP, Engineering. As of this morning the discharge pressure at Ullrich WTP was above 35 psi but in the low alarm state. I believe this will take a team approach to get to the root cause of this low pump station suction pressure issue. It may be as simple as a closed valve that we are not aware of or as technical as an undersized line to WCID # 10. I will ask Francisco to set up a meeting to address this issue with the team. Rick 3 P-TC
13 From: Mike Morin Sent: Tuesday, January 03, :59 AM To: Bart.JenningsCdci.austin.tx.us Cc: William Abshire; 'Water District 10' Subject: WD10 - Incoming PSI to Redbud Pump Station Bart, I have attached reports from August thru November showing specific dates, times and PSI in numbers. I will send you the December report in the morning. This should hopefully help in pinpointing the problems we are having. Let me know if you need any other information. Thanks, Mike Morin Crossroads Utility Services 2601 Forest Creek Drive Round Rock, TX mmorin@crossroadsus.com P-TC
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