20241010PAC to Staff 268-274.pdf

RECEIVED
Thursday, October 10, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
October 10, 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 17 (268-274)
Please find enclosed Rocky Mountain Power's Responses to IPUC 171' Set Data Requests 268-
274. Also provided are Attachments IPUC 271, 272, 273 and 274. The Confidential
Attachments are 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 [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
October 10, 2024
IPUC Data Request 268
IPUC Data Request 268
Referencing the Company's response to Staff Production Request No. 5,
Attachment IPUC 5, please provide an explanation for the following cleanup
projects, including the details of event, responsible parry, progress of clean up,
and expected completion date. Please include any workpapers in excel format.
(a) Portland Harbor Source Control.
(b) Bridger Oil Spill (New Releases).
(c) Bridger FGD Pond 1 Closure.
(d) Dave Johnston Oil Spill.
(e) Silver Bell/Telluride.
(f) Naughton Plant-FGD Pond 2.
(g) Ogden.
Response to IPUC Data Request 268
(a) Portland Harbor Source Control:
The Portland Harbor Superfund Site (PHSS)was added to United States
(U.S.) Environmental Protection Agency's(EPA)National Priorities List
(NPL) on December 1, 2000 (65 FR 75179). Since then, over 100 parties have
been named by the EPA as potentially responsible parties (PRP) for cleanup
action. The PHSS is an urban and industrial reach of the lower Willamette
River located immediately downstream of downtown Portland and extending
almost to the confluence with the Columbia River.
On February 16, 2011, PacifiCorp received a general notice letter under the
Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) indicating it had been named a PRP by the EPA for contamination
at the PHSS.
In its general notice letter to PacifiCorp, EPA identified properties presently
and formerly owned or operated by PacifiCorp which may have contributed to
contamination at the PHSS. PacifiCorp's main involvement in the PHSS is
within the River Mile 11E Project Area, which is located near facilities
currently or formerly owned or operated by PacifiCorp.
The EPA is the lead regulatory agency for investigation and cleanup of
sediment at the PHSS. The Oregon Department of Environmental Quality
(DEQ) and the City of Portland are the lead regulatory agencies for
identifying and addressing upland sources of contamination to the river. The
upland area at RM11E was identified as a potential source of contamination to
river sediments.

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 268
PacifiCorp entered into a Voluntary Agreement with the Oregon DEQ on
January 14, 2009, to evaluate its upland properties. PacifiCorp completed
source control evaluations at the PacifiCorp Albina Area Properties and the
Knott Substation. In 2010 and 2011, PacifiCorp implemented source control
measures at the Albina Substation and Knott Substation.
In 2010, PacifiCorp became a member of the Participation and Common
Interest (PCI) Group for the Portland Harbor Superfund Site. Along with
approximately 100 other PRPs, and with EPA's encouragement, PacifiCorp is
engaged in the PCI Group's voluntary effort to allocate cleanup liability and
costs associated with the entire PHSS.
In April 2013, PacifiCorp as well as five other PRPs associated with River
Mile 11E entered into an Administrative Settlement Agreement and Order on
Consent (ASAOC) with EPA to perform studies to inform the selection of the
remedial alternative for River Mile 11E. The other PRPs at River Mile 11E
include Cargill, Inc., the City of Portland, DIL Trust, Glacier Northwest, Inc.,
and Paramount Global (formerly ViacomCBS Inc.). These six parties are
referred to as the RM11E Group. The 2013 ASAOC was amended in
December 2017 to require the development of 100 percent design for the
RM11E Project Area.
Since April 2013, the RM11E Group has performed a series of extensive
investigations to assess the extent of contamination at the RM11E project area
to support remedial design. On June 30, 2023, the RM11E Group submitted
the draft Preferred Alternatives Report (PAR) to EPA that presents an
evaluation of remediation technologies for the RM11E Project Area,
consistent with the EPA Record of Decision (ROD) and related guidance and
concludes that sediment dredging and bank soil excavation will likely be the
single remedial technology employed between River Mile 10.9 and 11.6. The
PAR was approved by EPA on September 8, 2023 and serves as the 30
percent design for the RM11E project area. The RM11E Group is currently in
the process of conducting additional sediment and geotechnical sampling and
evaluations in preparation for the submission of a 60 percent design report to
EPA in late 2025/early 2026. It is anticipated that the 100 percent design
report will be submitted to EPA in 2026/2027. Implementation of the remedial
action at the RM11E Project Area has not been scheduled.
Following remediation of the PHSS, there will ongoing maintenance and
monitoring requirements in perpetuity.
(b) Bridger Oil Spill:
Explanation of the project-_In 1993, plant personnel at the Jim Bridger power
plant discovered a loss of fuel oil (diesel fuel#2) into the subsurface due to

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 268
one or more leaks in an underground pipeline. The pipeline was repaired, and
a fuel oil recovery system was constructed and has been operating since June
1999. This project was reviewed and approved by the Wyoming Department
of Environmental Quality (DEQ) Ground Water Pollution Control Program
(GPC). Modifications and updates to the recovery system have taken place in
the ensuing years.
The semi-annual monitoring program consists of 38 monitoring wells. There
are four active product recovery wells and three inactive recovery wells. As of
December 28, 2023, the fuel oils recovery system has recovered
approximately 151,820 gallons of fuel oil.
The amount of free product being recovered from the recovery system is
declining, indicating that the amount of recoverable free product is also
declining. It is anticipated to begin the operating of the air sparge system in
2025 for five years, with semi-annual groundwater monitoring continuing for
five additional years once the air sparging is deemed successful.
Responsible party—PacifiCorp and Idaho Power Company(IPC).
Expected completion date - End of 2035.
(c) Bridger FGD Pond 1 Closure:
Explanation of the project- The Jim Bridger power plant utilizes wastewater
ponds to manage coal combustion residuals (CCR), including flue gas
desulfurization (FGD) liquids from their emissions control processes.
Groundwater impacts have been identified downgradient of FGD Pond 1 and
FGD Pond 2 at the Jim Bridger power plant. This project includes the State of
Wyoming permit required groundwater monitoring and reporting as a result of
groundwater impacts from FGD Pond 1 and FGD Pond 2. The remediation of
the impacts and the Coal Combustion Residual monitoring and reporting is
managed under another environmental liability project. The closure of this
project relies on the State of Wyoming receiving primacy from the
Environmental Protection Agency and the State of Wyoming issuing
PacifiCorp a permit for each CCR unit. When that occurs the State of
Wyoming required sampling will cease. The Jim Bridger FGD Pond 1 and
FGD Pond 2 permit applications are anticipated to be sent to the State of
Wyoming in 2027.
Responsible party—PacifiCorp and IPC.
Expected completion date—2028.
(d) Dave Johnston Oil Spill:

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 268
Explanation of the project- In September 2010, approximately 2,000 gallons
of diesel fuel were released from an above ground storage tank into the
secondary containment area at the Ignition Oil Area. The released fuel was
recovered from the secondary containment area using a vacuum truck. Soil
within the containment area was removed down to the clay liner and
transported to the on-site Wyoming DEQ permitted petroleum contaminated
soils area for proper disposal. PacifiCorp entered into the Wyoming DEQ
Voluntary Remediation Program. The Wyoming DEQ concurred that
PacifiCorp should conduct quarterly groundwater monitoring as proposed in
the Site Characterization Report.
Prior to initiating quarterly groundwater monitoring, PacifiCorp detected the
loss of additional diesel fuel through inventory records in 2012. PacifiCorp
reported the release to Wyoming DEQ and immediately began to investigate.
In 2012, a light non-aqueous phase liquids (LNAPL) recovery system was
installed consisting of four recovery wells, an enclosure housing all of the
operational equipment for the recovery wells, and an above ground storage
tank for recovered LNAPL.
Petroleum hydrocarbons were detected during excavation work being
performed to locate utilities in October 2014. An Interim Action Work Plan
for impacted soil at the Fuel Pump Area was approved by Wyoming DEQ in
April 2015 following a subsurface soil assessment.
Toward the end of 2014 and beginning of 2015, PacifiCorp abandoned and
demolished three large above ground storage tanks at the Bulk Storage Area.
During the demolition and removal work,petroleum impacted soils were
discovered in the secondary containment structure for the tanks. Investigations
revealed that petroleum hydrocarbon impacted soils were found to be present
throughout the secondary containment structure from the ground surface to the
top of groundwater.
In 2015 and 2016 the Interim Action Work Plan was implemented at the
Former Fuel Pump Area and the Former Bulk Storage Tank Area. Impacted
soil was excavated and treated on site using ex-situ chemical oxidation.
The original Voluntary Remediation Project at the Ignition Oil Area was
expanded to include the Former Pump Area and the Former Bulk Storage
Tank Area.
Responsible party—PacifiCorp.
Progress of clean-up - Automated and manual LNAPL recovery operations
continue in the Ignition Oil Area. Semi-annual groundwater monitoring will
continue to occur at the Ignition Oil Area and Former Fuel Pump Area until

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 268
confirmation sampling is completed as part of plant closure. Semi-annual
depth to product and depth to water measurements will continue in this area to
ensure LNAPL does not exist.
Expected completion date—2029.
(e) Silver Bell/Telluride:
Explanation of the project- The Silver Bell Tailings Impoundment is owned
by PacifiCorp and is located in southwestern Colorado. The site is remote, at
high elevation (approximately 9,000 feet above sea level), subject to heavy
winter snow, and has no power or water supply. The tailings impoundment is
an undeveloped, inactive mill tailings disposal site that has the potential to
leach heavy metals and low pH discharge water. The impoundment contains
an estimated range of between 90,000 to 117,000 cubic yards of mill tailings
material that is now overlain by a vegetated cover system on the top surface
with a cover soil on the side slopes. In 1999, PacifiCorp submitted a
Voluntary Cleanup Plan (VCUP) application to the Colorado Department of
Public Health and Environment, which was subsequently approved.
Groundwater flows from above the site through the tailings impoundment and
ultimately discharges into the receiving Howard Fork. PacifiCorp performed
site characterization and reclamation activities to achieve acceptable erosional
and geotechnical stability of the tailings material and to help reduce sediment
and chemical impacts from the impoundment to surface water quality in the
Howard Fork. PacifiCorp has also installed additional Best Management
Practices (BMP) for increasing the pH in seepage being discharged from the
tailings impoundment, including installation of an Anoxic Limestone Drain.
PacifiCorp has also installed, maintained, and enhanced a treatment system
and settling ponds.
Responsible party—PacifiCorp.
Progress of clean-up - PacifiCorp is currently in litigation with CDPHE
regarding aspects (pH limits) of the October 2020 Discharge Permit that
PacifiCorp has deemed infeasible. PacifiCorp has submitted a Discharge
Permit Modification application to CDPHE to align iron discharge limits with
seasonal run-off that drastically changes discharge flows outside of
PacifiCorp's control. PacifiCorp is also modeling the Howard Fork to allow a
permit modification for Whole Effluent Toxicity test limits that PacifiCorp is
unable to meet due to reasons of treatment infeasibility.
Expected completion date - This project will be ongoing in perpetuity.
(f) Naughton Plant—FGD Pond 2:

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 268
Explanation of the project- The Naughton power plant utilizes wastewater
ponds to manage CCRs. CCR regulations, 40 CFR 257, require that CCR
impoundments meet certain closure standards when closing with CCR waste
in place as is the case with Naughton FGD Pond 2. One of these requirements
is evaluating any groundwater impact from CCR material in the closed pond
which requires ongoing monitoring of groundwater upgradient and
downgradient of CCR units. Groundwater impacts have been identified
downgradient of FGD Pond 1 and FGD Pond 2 at the Naughton power plant.
CCR regulations require that corrective measures be taken to demonstrate
compliance with groundwater protection standards. PacifiCorp has installed a
recovery trench downgradient of FGD Pond 2 and a horizontal drain capture
system below the FGD Pond 2 was completed and in operation in 2022. It is
expected that groundwater impacts will diminish within 13-15 years and the
liability will be closed after three consecutive years of groundwater sampling
with no groundwater protection standards.
Responsible party—PacifiCorp.
Expected completion date - 2040-2042.
(g) Ogden:
Explanation of the project- The Ogden Gas Company site is the location of a
former coal gasification facility which operated from 1889 to 1929. The
Ogden Gas Company, which began operation in 1889, was originally owned
by a predecessor to PacifiCorp and was sold to a predecessor of Questar Gas
Company who ceased its operations in 1929 and decommissioned the facility.
Site investigations since 1994 have demonstrated the presence of residual
contamination related to former gas plant operations. Investigation and
remediation of the Ogden Gas Company site is taking place under the
oversight of the Utah Department of Environmental Quality(DEQ), Division
of Environmental Response and Remediation, Voluntary Cleanup Program. A
2014 remediation effort in the former gashouse area removed tar wells,
piping, and other subsurface features associated with the gashouse as well as
shallow contaminated soils to depths of 12-16 feet below ground surface. As
part of the excavation effort, a bentonite slurry wall was placed to a depth of
32 feet which encircles the 2014 excavation area and impedes groundwater
flow and contaminant migration through the former gashouse area. Due to
limiting factors during the excavation effort, some soil contamination remains
in place. Quarterly and more recently semi-annual groundwater monitoring
has occurred since February 2016. Additional soil vapor and indoor and
ambient air investigations have occurred in 2018, 2020, and 2023. Initial
estimates assumed the site would be able to complete a risk-based closure in
2026. Based on recent investigations, PacifiCorp is working with DEQ/
DERR/VCP to develop plans that will allow a risk-based closure of the

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 268
liability site. DEQ /DERR/VCP will likely require additional monitoring
wells and studies which could prolong the 2026 estimated closure date.
Responsible party—PacifiCorp, Questar Gas Company,Naylor Family
Investment and Ogden Auto Body, Inc.
Expected completion date—2026.
Recordholder: Jackie Wetzsteon/ Scott Wetzel
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 269
IPUC Data Request 269
Referencing the Company's response to Staff Production Request No. 11,
Attachment IPUC 11, please provide an explanation for the following Injuries and
Damage claims. Please provide invoices and supporting documentation for each
claim.
(a) Claim Number: 40002186.
(b) Claim Number: 70002333.
(c) Claim Number: 40002193.
(d) Claim Number: 40002190.
(e) Claim Number: 40002203.
(f) Claim Number: 70002353.
Response to IPUC Data Request 269
(a) Please refer to Confidential Attachment IPUC 269-1.
(b) Claim payment for fire damage to an brand new apartment building caused by
Pacific Power electrical installation error. Please refer to Confidential
Attachment IPUC 269-2.
(c) Please refer to Confidential Attachment IPUC 269-3.
(d) Please refer to Confidential Attachment IPUC 269-4.
(e) Please refer to Confidential Attachment IPUC 269-5.
(f) Claim payment for damages to a hotel caused by failed Pacific Power
equipment which caused equipment damage in a hotel. Please refer to
Confidential Attachment IPUC 269-6.
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: Marlow Voss /Landon Gobelman
Sponsor: Mariya Coleman

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 270
IPUC Data Request 270
With reference to Exhibit No. 48, Tab 4.2.2, please explain the difference
between the Annual Incentive Plan, and Bonuses and Awards. Please include in
your response specific metrics or merits used to determine employee bonuses and
award amounts. Please include workpapers in excel format to justify your
response.
Response to IPUC Data Request 270
Please refer to Confidential Attachment IPUC 177 and Confidential Attachment
IPUC 270 which provides information regarding PacifiCorp's Annual Incentive
Plans (AIP) for 2023 and 2024, respectively.
Please also refer to Confidential Attachment IPUC 270 which provides
information regarding PacifiCorp's STARS Awards.
Performance awards, given at the discretion of management, are payments in
recognition of outstanding work. All employees are eligible to receive this award.
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: Shelley Zoller
Sponsor: Julie Lewis

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 271
IPUC Data Request 271
Referencing the Company's response to Staff Production Request No. 4,
Attachment IPUC 4-8, please explain the increase in Administrative and General
Salaries of approximately $8.9 million from Calendar Year 2022 to 2023. Please
include work papers in excel format to justify your response.
Response to IPUC Data Request 271
Administrative and General (A&G) salaries increased approximately $8.9 million
from calendar 2022 to 2023 due to increased headcount, annual merit, higher
employer 401k expense, payroll tax and other costs partially offset by lower
severance and long-term disability expense. In addition, 2022 expense included a
favorable deferred compensation adjustment. Please refer to Attachment IPUC
271 which provides details by general ledger(GAL) account.
Recordholder: Sheila Diver
Sponsor: Nikki Kobliha

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 272
IPUC Data Request 272
Referencing the Company's response to Staff Production Request No. 4,
Attachment IPUC 4-8, the Company's Outside Services Employed increased from
approximately $41.1 million in 2022 to approximately $49.2 million in 2023.
Please provide a listing of all expenses included in the $49.2 million charged to
the Company's jurisdiction and show how those amounts were allocated.
Response to IPUC Data Request 272
Please refer to Attachment IPUC 272.
Recordholder: Sheila Diver
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 273
IPUC Data Request 273
Please provide a copy of the Company's policy for corporate aircraft use.
Response to IPUC Data Request 273
Please refer to Attachment IPUC 273.
Recordholder: Carrin Larsen
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
October 10, 2024
IPUC Data Request 274
IPUC Data Request 274
Please provide a copy of the flight logs for the Company aircraft in 2023.
Response to IPUC Data Request 274
Please refer to Attachment IPUC 274.
Recordholder: Maxwell Yamagishi
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
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' response to IPUC Set 17 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 10ffi day of October, 2024.
Respectfully submitted,
By
Joe Dallas
Senior Attorney
Rocky Mountain Power
2