HomeMy WebLinkAbout20241004PAC to Staff 257-260 (Redacted).pdf RECEIVED
Friday, October 04, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 4, 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 15 (257-260)
Please find enclosed Rocky Mountain Power's Responses to IPUC 151' Set Data Requests 257-
260. The Confidential Attachments and Confidential Responses will be provided via BOX.
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(801) 220-2313.
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&gmail.com
Brad Heusinkveld/ICL bheusinkveld(a�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
October 4, 2024
IPUC Data Request 257
IPUC Data Request 257
In reference to Response to Production Request No. 189 and Attachment 55-1 in
Response to Production Request No. 55, the actual cost($2.5 million) for the UO
—Mill Blanket—2023 project is over the $1.6 million project budget by $0.9
million. Please explain the causes for the cost overage and provide any documents
or evidence supporting them.
Confidential Response to IPUC Data Request 257
The cost overage of the UO—Mill Blanket—2023 was due to additional issues
with the Dave Johnston Unit 1 #4 Pulverizer Grinding Zone replacement and
Dave Johnson Unit 3 "D"Mill roll replacement projects.
When the appropriation request(APR) for the Dave Johnston Unit 1 #4 Pulverizer
Grindin Zone re lacement was issued
The APR estimate was 165,677 and the actual expenditures were
$730,605.
The APR for the Dave Johnson Unit 3 "D"Mill Roll Re lacement was for the
The APR estimate was $195,582 and the
actual expenditures were $1,055,051.
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: Alan Dugan/Karl Mortensen
Sponsor: Brad Richards
PAC-E-24-04/Rocky Mountain Power
October 4, 2024
IPUC Data Request 258
IPUC Data Request 258
In reference to Response to Production Request No. 190 for the 301 Generator
Stator Rewind project, please provide the contract agreement with Siemens
including the scope of work, contract price, a breakdown of the price by the work
breakdown structure, and schedule.
Response to IPUC Data Request 258
Please refer to Confidential Attachment IPUC 258 which includes the contract
terms, pricing, scope, and schedule for the project.Note: the agreement is labeled
as a Change Order because Siemens was already on site for other overhaul work,
and when the need arose to do the stator rewind, Siemens became the best option
to complete the work that was needed. In addition to the pricing listed in
Confidential Attachment IPUC 258, some additional extra work authorizations
(change orders)were also needed. Please refer to the Company's response to
IPUC Data Request 190 which included the change orders associated with the
referenced additional extra work authorizations.
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: Paul Pulli
Sponsor: Brad Richards
PAC-E-24-04/Rocky Mountain Power
October 4, 2024
IPUC Data Request 259
IPUC Data Request 259
6ii0iiior
reference to Res onse to Production Request
Y 22-23 ro'ect
exp am w et er t e Stator Repair Forced
Outage Change Order is part of the U2 Stator Rewind project or if the Change
Order is for a different project, altogether. Please provide the details of this credit
including which project will be credited, the name and number of the project, the
change order number, and whether this project is one that has already been
implemented, currently being implemented, or for a future project.
Confidential Response to IPUC Data Request 259
ME
N
was issued on an invoicRtot Stator RepaiPForce WDpurc
order(PO). Please refer to Confidential Attachment IPUC 259.
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: Aric Hunter
Sponsor: Brad Richards
PAC-E-24-04/Rocky Mountain Power
October 4, 2024
IPUC Data Request 260
IPUC Data Request 260
Please provide the confidential information that was redacted from Response to
Production Request No. 192. Additionally, please provide a breakdown of the
actual cost of the U2 Stator Rewind CY 22-23 project by the contract costs,
internal labor, AFUDC, etc.
Response to IPUC Data Request 260
The Company has confirmed with Idaho Public Utilities Commission (IPUC) staff
that they were able to obtain all of the confidential information included with the
Company's response to IPUC Data Request 192.
Please refer to Confidential Attachment IPUC 260 which provides the breakdown
of the U2 Stator Rewind project costs.
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: Karl Mortensen
Sponsor: Brad Richards
Joe Dallas (ISB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: 3 60-5 60-193 7
Email:joseph.dallas@pacificorp.com
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
senior 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 the Company's responses to IPUC Set 15 contains Company proprietary information that
could be used to its commercial disadvantage.
1
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in 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 7 h day of October, 2024.
Respectfully submitted,
11-
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
2
Joe Dallas (ISB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: 3 60-5 60-193 7
Email:joseph.dallas@pacificorp.com
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
senior 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 the Company's responses to IPUC Set 15 contains Company proprietary information that
could be used to its commercial disadvantage.
1
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in 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 7 h day of October, 2024.
Respectfully submitted,
11-
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
2