16
SCHMELTZER, APTAKER & SHEPPARD, P.C, \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV r_A», r CHIP II] T*L«C AOCAn CHBIITOWM HAWI .1 TMO»« (IIUMUI. C-kt ^ "' ^^ *"J9I? IIM MICHMl. IHtPAflt (2O3O2OHOOO NOMffT U IIM MOHAr MTT7 i pyour May l, 19B6 -ftOTAOMITTfOmOC VIA FEDERAL EXPRESS Ellen c. Teplitzky, Esquire Assistant Regional Counsel U.S. Enviornmental Protection Agency Region III 841 chestnut Building Philadelphia, Pennsylvania 19107 Re: Army CreeX Feasibility Study Dea- Ellen: As a followup to our recent telephone conversation, I have enclosed copies of several documents which demonstrate that any "shortfall" at Artesian Water Company's Llangollen Well Field has been more than satisfied by interconnections and new wells already placed into service by Artesian. These documents, which are formal submissions by Artesian to the Delaware Public Service Commission, further support the discussion on pages 2-4 and 2-5 of the Army Creek Feasibility Study submitted by New Castle County under cover letter dated March 7, 1986. Please note that the attached index provides a fuller description of the enclosed documents. Do not hesitate to contact me if you have any questions concerning this matter. Very truly yours, Wm. Roger Truitt Enclosures WRTibb RR301303 r.1

COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

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Page 1: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

SCHMELTZER, APTAKER & SHEPPARD, P.C,\ COUNSELORS AT LAW

IBOO MASSACHUSETTS AVENUE, NORTHWESTimm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79(PWU*P,J INCMARD IV r_A», r CHIP II] T*L«C AOCAn CHBIITOWM HAWI.1 TMO»« (IIUMUI. C-kt "' ^ *"J9I?IIM MICHMl. IHtPAflt (2O3O2OHOOO

NOMffT U IIMMOHAr MTT7

i pyour

May l, 19B6-ftOTAOMITTfOmOC

VIA FEDERAL EXPRESS

Ellen c. Teplitzky, EsquireAssistant Regional CounselU.S. Enviornmental Protection AgencyRegion III841 chestnut BuildingPhiladelphia, Pennsylvania 19107

Re: Army CreeX Feasibility Study

Dea- Ellen:

As a followup to our recent telephone conversation, Ihave enclosed copies of several documents which demonstrate thatany "shortfall" at Artesian Water Company's Llangollen Well Fieldhas been more than satisfied by interconnections and new wellsalready placed into service by Artesian. These documents, whichare formal submissions by Artesian to the Delaware Public ServiceCommission, further support the discussion on pages 2-4 and 2-5 ofthe Army Creek Feasibility Study submitted by New Castle Countyunder cover letter dated March 7, 1986.

Please note that the attached index provides a fullerdescription of the enclosed documents. Do not hesitate to contactme if you have any questions concerning this matter.

Very truly yours,

Wm. Roger Truitt

Enclosures

WRTibb

RR301303

r.1

Page 2: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

ORIGINAL([«"".

Document Index

A. Excerpts from Artesian Hater Company 1974 Annual Report- Statement of President and Chairman Ellis D. Taylor,dated March 14, 1975.

•Cnce we place the additionalsources of supply now beingdeveloped into use, we will havemore than ample productioncapability and thereby eliminate thesupply problems precipitated by theunforeseen and unfortunate need toso drastically reduce our pumpage atLlangollen in 1973."

B. Excerpts from Direct Testimony of B. T. Lakshman, ChiefEngineer, Artesian Water Co. , filed with Delaware PublicService commission, Docket No. 82-80 on May 28, 1982,including Exhibit Nos. 3 and 5.

"Artesian has four directinterconnections with the otherwater purveyors in the area whichwill help augment its supply up to3.6 million gallons per day."(P- 4)"Since 1973 Artesian has drilledas many as 140 exploratory testwells and constructed 16 productionwells. The total capacity of wellsupplies developed from thisintensified exploration programequals some 9.5 million gallons (perday)." (p. 6)

C. Excerpts from Direct Testimony of Peter N. Johnson, VicePresident and General Manager, Artesian Water Companyfiled with Delaware Public service Commission, DocketNo. 82-80 on May 28, 1982.

"Our supplies can be augmented bythe daily purchase of up to 3.6million gallons throughinterconnections with the City ofWilmington and Wilmington SuburbanWater Corporation." (p. 9)

A R 3 0 I 3 I O

Page 3: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

(for:

•jj ^ H

A R 3 0 I 3

Page 4: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

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Page 6: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

*vBEFORE THE PUBLIC SERVICE COMMISSION ( \OF THE STATE OF DELAWARE B> 'r (Red)

IN THE HATTER OF THE REVISION OF RATESFILED BY ARTESIAN WATER COMPANY

DIRECT TESTIMONYOF

BANGALORE T. LAKSHMAN

MAY 1982

oAR30I3U

Page 7: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

ORIGINAL.--> TESTIMONY OF BANGALORE T. LAKSHMAN, P,E. (Red)

Q. Please state your name and t.'dress.

A. My name Is Bangalore T, Lakshman. I reside ac 22 Chiming Road, New

Cascle, Delaware,

Q. What is your occupation?

A. I am Chief Engineer of Artesian Water Company.

Q. Please provide a summary of your educational and professional

background.

A. I was awarded a B.S. degree in civil engineering from the Uni-

versity of Mysore, India; a master's degree in water resources

development, leading to specialization in ground water and surface r

water hydrology, from the University of Roorkee, India; and a

master's degree in civil engineering, leading to specialization in

water resources, hydraulics and environmental engineering, from the

University of Delaware, Newark, Delaware1,

Upon graduation from college, I served as a junior engineer

for the Public Works Department, Mysore, India, until 1964. At

that time I Joined the faculty of the University College of En-

gineering, Bangalore, India, and started teaching until 1963, Then

in 1968 I became a research fellow and teaching assistant at the

University of Delaware while obtaining my M.S. degree in civil

engineering. Since October 1971, I have been employed by Artesian

Hater Company—first as its hydraulics and water quality engineer

and in 1973 I was promoted to my present position as chief engineer.

While employed at Artesian, I have completed numerous assign-

ments in th.e area of water resources development, water quality and

) management. I have performed several cost analyses and feasibility

studies for acquiring private water systems, as well as feasibility

A R 3 0 I 3 I 5

Page 8: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

nil

"3" • ORIGINAL(Red)

Engineers, Delaware Society of Professional Engineers, National

Hater Well Association, and International Hater Supply Association. .

I served as president of the Delaware Society oi Professional

Engineers (New Castle Chapter) as well as ics Secretary, State

Director, President Elect, and Past President during the period

1977-1982.

Q. Have you published any articles or technical papers in the area of

water resources, water quality, supply, operation an: management?

A. Yes. I have several publications to my credit. A list of them can

be found In the attached supplemental Statement of Qualifications

(BTJ. Exhibit 1).

Q. In what areas do you propose to present testimony today?

A. My testimony will focus on Artesian Water Company's water resources

development and management, available supply, customer demand,

operation, water quality management and related aspects.

Q. Please briefly describe Artesian's water system,

A. Artesian Water Company's water system extends over 90 square miles

in the northern part of Hew Castle County. It serves about 36,500

customers covering a population of over 130,000 people. Its primary

source of supply is ground water, and it has 41 operating

wells with a total theoretical capacity of 15.5 million gallons per

day. The Company has 17 storage tanks with a total systen storage of

27 million gallons, of which about IB million gallons is considered to

be a live storage. The water system is divided Into seven service

levels to provide acceptable pressure gradients to Arteslan's

customers who are located at ground elevation ranging fron sea

level to elevation 420. It has 12 booster punping station!. The

water systen consists of about 510 miles of pipe lines fr:r, 2" to

A R 3 0 I 3 I 6

Page 9: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

ct I

I

20" in diameter and about 1.5CC hydrants. Artesian has four direct

interconnections wich the other water purveyors in the area which

will help augment its supply up to 3.6 million gallons per day. During 1981

Artesian 'a average daily demand and peak day demand amounted Co

11.3 million gallons and 14,5 million gallons, respectively. In

addition, Artesian is also considering developing new interconnec-

tions with the Chester Water Authority and the City of Hilmingcon

to further augment its source of supply to meet its future customerdemand,

Q. Could you briefly describe the operation of Artesian1 s watet nysten?

A, Artesian derives about 702 of its ground water supplies from itsrwells located in the coastal plain. The remaining 302 of its wells

are in the Piedmont area, The water supplies from the coastal

plains has low pH and high carbon dioxide and is considered to be

soft water, The water supply from the Piedmont area has relatively

high pH, low carbon dioxide, and is considered to be hard water.

Therefore, Artesian has to treat its source of well supplies wit*.-

aeration, pH adjustment, chlorlnation and flouridation to meet

State as well as Federal water quality standards. Three of its

wells have to be treated for iron through an iron removal plant to

meet the regulatory standards. Artesian has a complex water system

since it has to treat its water supply In 16 different places.

Therefore, Artesian's operation is manned around-the-clock in three

6-hour shifts. The operators are guided by the fluctuations in

A R 3 0 I 3 I 7

Page 10: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

y®BBB gffldj$]

Exhibit 6.

AK30I3I8

i'\'

"••r>rn .tit*,

-6- ,. OkJGINAl(Red)

only up to a maximum of 2 ngd from this wellfield. In this connec-

tion Artesian has filed a suit against the New Castle County govern-

ment seeking substantial aaoagcn.

Q. Since the time of curtailment of pimping from Llangollen, what did

Artesian do in developing additional ground water supplies?

A. Since 1973, the year in which Artesian was asked to curtail the

•mount of pumpage from its Llangollen wellfield, several studies

have been commissioned by Artesian to assess potential veil sites

and to explore for additional and alternate sources of supply, A

list of studies commissioned in this connection Is nosed in BTL

Exhibit 2.

The studies have identified the locations of potential new

well sites. Artesian has generally proceeded in accordance with

the studies' recommendations and drilled a series of exploratory

test wells. Since 1973 Artesian has drilled as many as 140 ex-

ploratory test wells and constructed 16 production wells. The

total capacity of well supplies developed from this intensified

exploration program equals some 9.5 million gallons (6,f''i gallons•

per minute). A schedule showing the yearly well exploration and

development statistics is attached as BTl Exhibit 3,

Q. Has Artesian made a significant financial commitment to explore for

new sources of ground water supplies?

A. Yes, it has. The importance with which Artesian views its well

supply exploration program is evidenced by its financial commitment

in excess of $1.3 million, not including concomitant expenditures

for supply mains, treatment facilities, etc. A statement showing

Artaslan's capital expenditures in this regard is attached as BTL

G

Page 11: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

Sj,„.,.!,);'

"9" , ORIGINAL !|;(Red)

Gannett Fleming Corddry iCarpenter, Inc. . . . . . . . . . . . . . 22 mgd

Department of Natural Resources 4Environmental Control, Delaware . . . . . 18.5 mgd

Water & Sewer Management Office ofNew Castle County (Water ResourcesAgency) ................. 17.5 Bgd

Q. What is the status of Artesian's efforts in developing additional

sources of supply through interconnections?

A. Since 1973 Artesian has completed four interconnections with the

City of Wllmlngton and one Interconnection with Wilmington Suburban

Water Corporation. The location, date of construction, and capacity

of the existing and proposed interconnections are 11,"..id in BTL

Exhibit S. . '

0,. In the absence of interconnections and purchased water, what alter-

natives does Artesian have in meeting future customer demand?

A. In the absence of purchased water through interconnections, to meet

ongoing future customer demands Artesian has to either Halt the

supplies to its customers or develop expensive alternate sources of

supply.

Q, Would you please describe the kind of procedure and practice

Artesian follows in making decisions as to the purchase of water

through Interconnections.

A. Artesian does have a set of procedures and guidelines for making

decisions as to the aspect of periodic purchases of water from its

interconnections. Normally I set those guidelines for the benefit

of operating supervisors and operators, These guidelines are

reflected in my periodic memoranda to concerned operating personnel

concerning use of interconnections, I would like to submit my

latest menorandua in this connection tf~ Exr.lbtt 6,

AR30I3I9

Page 12: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

WILL E;(?LORATION ANO DEVELOPED CAPACITY

*6,600 gpro • 9.5 r.cj

YEA.1

1973

1974

1975

1976

1977

1978

1979

1930

1931

T07AL

KILLS DRILLEDr TESTWILLS

27

50

It

7

21

It

4

5

7

139

PSOS'.'CTWSWILLS

2

2

1

3

1

1

1.

3

2

16

DEVELOPEDCAPACITY (C?>!)

700

500

350

. 1,700

250

400

100

1,600

1,000

6,600*

LOCATION OFPSODL'CTIOX BELLS

C-l Hockessin, Ucll J5Glecdale

Well 16 Cleniiale, Hockesain0-3

Well 11 at Ftltvinds

Replacement Well Hi,Jefferson Faras; ClendaleHI (Moor as Fara) , HockesuinWell (4

Caravel Faru

Well 51, Collini Park(Replacecenc)

Well 04 a: Clendale(Replacement)

Well l?4, Fair.-inds(Replace?,er.c), Hells 91 &(2, Aniaan's Village

Eastern States 01 & 02

ET'- Exhibit No, 3

AR30I320

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Ic u

IIORIGINAL(Red)

.-H ,S 0.

.^ e — • «) i-7, |S U W= - ra n

r - X

•np w« •r*'H Tt-n «H <»Htp* .£ ^:2 OJ rH "1H3 ul (j 3 o 3 O3 3 3 u » c < s W O3

T. T( o

AR30I32I

•••"«*»,

Page 14: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

~H&1iw1M:

BEFORE THE PUBLIC SERVICE COMMISSIONOF THE STAlii OF DELAWARE

IN THE MATTER OF THE REVISION OF RATESFILED BY ARTESIAN WATER COMPANY

DIRECT TESTIMONYOF

PETER N. JOHNSON

NAY 1932

AR30I322

^ ."•_ ,'

Page 15: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

tTESTIMONY OF MR. PETES N. JOKiSON

Q. What la your name and address?

A. My name la Peter N. Johnson. I reside at 305 Caravel Drive, Bear,

Delaware.

q. What Is your occupation?

A. I am Vice President & General Manager of Artesian Water Coopany.

q, Would you give us a summary of your educational and professional

background?

A. I an a graduate of Northeastern Univs"slty, Boston, Massachusetts,

with a Bachelor of Science Degree in Civil Engineering. I am a

registered Professional Engineer in Illinois by examination and am

also a registered Professional Engineer in Ohio, Pennsylvania, New (i

Jersey, New Hampshire, New York, Maine, and Delaware. I an certi-

fied by the State of Illinois as a Class A Public Water Supply

Operator. I am a member of the National Society of Professional

Engineers and the New Castle Chapter of the Delaware Society of

Professional Engineers, New England Water Works Association,

Maine Hater Utilities Association, American Water Works Association,

and National Association of Hater Companies.

While attending Northeastern University, I was employed during the

last four years of the five-year cooperative training program

by the Heymouth Water Works In Keynouth, Massachusetts. The co-

operative training program consists of alternate 10 and 15-veek

classroom-work periods in which the student gains practical work ^"^

experience in a field allied to his studies. Frequent evalua:i:r,=

AR30I323

Page 16: COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST … · \ COUNSELORS AT LAW IBOO MASSACHUSETTS AVENUE, NORTHWEST imm»oiHUTii> WASHINGTON, D.C, 2OO36-IB79 (PWU*P,J INCMARD IV

-g.

,->. consumption and growth trends, efforts to improve the effectiveness

of Company operations, the mechanics and reasons for a water adjust-

ment clause, '"..id none proposed minor revisions to Artesian' s Rules

and Rates, I an also prepared to discuss as necessary ocher aspects

of Artesian 's operation and management in general.

Q. Please describe the Artesian water system and plant.

A. The present Artesian service area extends over 90 square miles from

the Pennsylvania state line west of the City of Wilnington, south-

easterly and southwesterly in a half moon approaching the Maryland

line and the CiD Canal.

Artesian serves an estimated population of over 130,000 people

through 511 miles of pipeline up to 20" in diameter with over 1,500-s

fire hydrants in seven different pressure levels ranging from sea

level to an elevation of 420 feet near the Pennsylvania line.

There are 61 operating wells in the system. Distribution storage

consists of 17 tanks with a total design capacity in excess of 27

million gallons. Our supplies can be augmented by the daily purchase

of up to 3.6 million gallons through interconnections with the City

of Wilmington and Wilmington Suburban Hater Corporation. Ac the

present tine we are in discussions with the City of Wilraington con-

cerning possible additional Interconnections in order to increase the

availability of purchased water from the City, Over a longer term,

a planned four mile, 24" connection with Chester Water Authority

will Initially allow for average daily purchases of 2,0 mgd and a

peak of 3 ngd, increasing to an average of 6.0 and a peak of 9.0 ngd,

^ :?. 19:1, Artesian's average daily demand vas 11.3 million gallons

w::h, a peak day of U,5 million gallons. Attached as Exhibit PNJ 1

•:.,———— a o f A r : , AR30I321*