20240816PAC to Staff Supplemental No. 58_79.pdf.pdf

RECEIVED
Friday,August 16, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 16, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
monica.barrio ssanchez(apuc.Idaho.gov
S ecretarygpuc.idaho.gov
RE: ID PAC-E-24-04
IPUC Set 5 (58-81)
Please find enclosed Rocky Mountain Power's 1st Supplemental Responses to IPUC 56, Set Data
Requests 58 and 79. Provided via BOX are Confidential Attachments IPUC 58 1st Supplemental
and 79 1st Supplemental. Confidential information is provided subject to protection under
IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject to the non-
disclosure agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA elo(&echohawk.com(C)
Lance Kaufman/IIPA lancekae.isg insi hg t.com(C)
Matthew Nykiel/ICL matthew.nykiel&amail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Thomas J. Budge/Bayer ti(&racineolson.com(C)
Brian C. Collins/Bayer bcollins(&consultbai.com
Greg Meyer/Bayer gmeyerkconsultbai.com
Kevin Higgins/Bayer khig gins kenergystrat.com(C)
Neal Townsend/Bayer ntownsendkenergystrat.com (C)
Ronald L. Williams/PIIC rwilliams(&hawleytroxell.com

Brandon Helgeson/PIIC bhelgeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinskmwanalytics.com
Val Steiner/PIIC val.steiner(a-)itafos.com
Kyle Williams/PIIC williamsknasbyui.edu

PAC-E-24-04/Rocky Mountain Power
August 16, 2024
IPUC Data Request 58 — I"Supplemental
IPUC Data Request 58
Please provide the following information for the Jim Bridger—U 1 Conversion to
Natural Gas project referenced on Page 8.5.3 Exhibit No. 48 of McCoy's
Testimony. Please include any available workpapers with formulas intact. If any
of the information requested below cannot be provided or is not available, please
explain why it is not available or cannot be provided.
(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(c) If a Request for Proposal (RFP) or Request for Quote (RFQ) was submitted,
please provide the following:
I. A copy of the RFP or RFQ that was submitted;
II. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
III. The short-list bidder scorecard; and
IV. A copy of the winning bid.
(d) Please provide the approved Initial Project Plan including the following:
I. Initial project scope;
II. Initial project budget;
III. Initial proposed schedule; and
IV. Evidence that the Initial Project Plan and budget were approved at
the appropriate level.
(e) Please provide the following for the Baseline Construction Project:
I. Baseline project scope;
II. Baseline project budget broken down by Work-Breakdown
Structure (WBS);
III. Baseline project schedule broken down by WBS;
IV. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the
differences, explain the reason for the change, and provide
evidence that the changes were approved at the appropriate level;
V. Project status reports and action items; and

PAC-E-24-04/Rocky Mountain Power
August 16, 2024
IPUC Data Request 58 — I"Supplemental
VI. Contractor change orders.
(f) Please provide the following related to completion of the project:
I. Baseline construction budget-to-actual comparison by WBS and by
year;
II. Baseline construction schedule-to-actual comparison by WBS;
III. For any budget-to-actual cost overages by major WBS category
that is over 5%, please explain the reason for the differences and
provide evidence that the amount was approved at the appropriate
level; and
IV. iv) Please explain any slips in schedule from the baseline
construction schedule.
I't Supplemental Response to IPUC Data Request 58
Further to the Company's response to IPUC Data Request 58 dated August 9,
2024, and to the email received from Idaho Public Utilities Commission (IPUC)
staff on August 15, 2024, the Company provides the following additional
information:
(a) Detailed information on the bids received for each type of work or expense for
the project, including any contracted engineering and construction (i.e. Boiler
Overhaul/Burner Construction)work, and materials, including:
I. Each bid proposal with price and schedule;
II. Scorecard for shortlist bidders and evaluation criteria to select winning
bidder;
III. Final agreement with the winning bidder including price and schedule.
The requested information above is highly confidential and commercially
sensitive. The Company requests special handling. Please contact Mark Alder
at(801) 220-2313 to make arrangements to review.
(b) Change order documents for the Fuel Delivery Construction, specifically:
1. 3300005762-160 WY3040C-CCN-006 HP skid to Control
2. 3300005762-150 WY3040C-CCN-009 Fuel Train Add Socket Welds
3. 3300005762-130 WY3040C-CCN-010 Upper Hot Air XOVER Duct
(c) Change order documents for the Insulation, specifically:
1. 3300005762-140 WY3040C-CCN-011 U2 Nitrogen Purge
2. 3300005762-170 WY3040C-CCN-014 Additional infill steel
3. 3300005762-180 WY3040C-CCN-015 ABD Infill steel mods

PAC-E-24-04/Rocky Mountain Power
August 16, 2024
IPUC Data Request 58 — 1st Supplemental
4. 3300005762-190 WY3040C-CCN-017 Unit 1 copper lines
5. 3300005762-200 WY3040C-CCN-018 Unit 1 Delay, other T&M-Work
(d) Change order documents for the Material and Engineering, specifically:
1. 3300005374 CO#2 and First Amendment to Contract
2. 3300005374 CO#3 Babcock Power Services, Inc. PA Fan Outlet Dampers
3. 3300005374 CO#4 Babcock Power Services, Inc. Scanner Elimination
4. 3300005374 CO#5 Babcock Power Services Inc. Filter Skid—FE
5. 3300005374 CO#6 Babcock Power Services, Inc. Heating System FE
6. 3300005374 CO#7 Babcock Power Services Inc. -Burner Tips—FE
(e) Any other change orders for U1 and U2 Conversion to Natural Gas Project.
Please refer to Confidential Attachment IPUC 58 lst Supplemental which provides
copies of the above listed change order documents. Note: the construction change
notices (CCN) listed above in subparts (b) and(c) above initiate the process for a
change order. Often, a single change order will be issued to cover multiple CCNs
which is the reason for different numbering of the documents provided and the
CCNs listed above.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement(NDA)executed in this proceeding.
Recordholder: Ken Cutler
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 16, 2024
IPUC Data Request 79 — I"Supplemental
IPUC Data Request 79
In the Company's Response to Production Request No. 15 —Attachment, "Field
Ai-Field Asset Intelligence" has a total cost of$20,563,043. Please explain if that
cost is Idaho allocated and at what percentage. If not, please provide Idaho
allocated expenses. Additionally, please answer the following:
(a) Please provide a detailed explanation for the need of the project, including the
analysis justifying the need.
(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected from among the
alternatives supported by the Company's economic analysis (costs and
benefits) comparing them.
(c) If a RFP or RFQ was submitted, please provide the following:
I. A copy of the RFP or RFQ that was submitted;
II. A detailed explanation of the selection process including the
scorecard and list of the criteria used to select the project;
III. The short-list bidder scorecard; and
IV. A copy of the winning bid.
(d) Please provide the approved Project Plan including the:
I. Initial and Actual project scope;
a. Initial Scope:
b. Actual Scope:
II. Initial project budget;
a. Initial Budget:
III. Actual project cost;
a. Actual Cost:
IV. Initial and Actual schedule;
a. Initial Schedule:
b. Actual Schedule%
V. Evidence that the Initial Project Plan a nd budget were approved at
the appropriate level;
VI. Please explain any differences in budget to actual project costs;
and

PAC-E-24-04/Rocky Mountain Power
August 16, 2024
IPUC Data Request 79 — 1st Supplemental
VII. Please explain any slips in schedule from the baseline construction
schedule.
1st Supplemental Response to IPUC Data Request 79
Further to the Company's response to IPUC Data Request 79 dated August 14,
2024, the Company provides the following additional information responsive to
subpart(c).
(c) Please refer to the Company's responses to subparts I. Through IV. below:
I. A request for proposals (RFP) for the work management solution was
facilitated by a Berkshire Hathaway Energy Company(BHE) affiliate.
Through that in-depth process IBM Maximo was the chosen solution for
work management at the BHE level, alongside Accenture as the chosen
implementation partner. Post-RFP, Accenture spent time with
PacifiCorp to confirm understanding of the PacifiCorp specific
requirements and scoping for the Maximo implementation.
II. Please refer to Confidential Attachment IPUC 79 1st Supplemental.
III. The short-list bidder scorecards: Please refer to Attachment IPUC 79,
document"RFP—Delivery WMIS —Evaluation Matrix" and"WMIS
Implement— Scoring Matrix"
IV. Please refer to Attachment IPUC 79 lst Supplemental.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's
Rules of Procedure No. 67—Information Exempt from Public Review, and
further subject to the Non-Disclosure Agreement(NDA) executed in this
proceeding.
Recordholder: Amanda Lindsay/Drew Smith
Sponsor: To Be Determined

Joe Dallas (ISB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:[e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-24-04
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY
AUTHORITY TO INCREASE ITS ) RELATING TO DISCOVERY
RATES AND CHARGES IN IDAHO ) RESPONSES
AND APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power,through its response, is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the first supplemental response to IPUC Data Request Nos. 58 and 79 contains
Company proprietary information that could be used to its commercial disadvantage.
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Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.
DATED this 16th day of August, 2024.
Respectfully submitted,
By 'c
Joe Dallas
Attorney
Rocky Mountain Power
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