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HomeMy WebLinkAbout20040521Responses of Avista to Staff.pdfAvista Corp. 1411 East Mission PO Box 3727 Spokane, Washington 99220-3727 Telephone 509-489-0500 Toll Free 800-727-9170 HECE IV ED (1) H""EO 2fiUl.t1A 121 AM 9: ~~' 'V'STA~ Corp. March 20, 2004 iLl (IU (uuL!e UTiLiTIES COi"if'1fSStOM Idaho Public Utilities Commission 4 72 W. Washington St. Boise, ill 83720-0074 1\ttn: Scott Woodbury Deputy 1\ttomey General Re:Production Request of the Commission Staff in Case Nos. 1\ VU-04-01 and 1\ VU-04- Mr. Woodbury, I have attached an original and three copies of 1\ vista s response to Staff Data Request No(s). 96b-Supplemental, 246 through 253, 259, 262, 263 , 264, 248(C), 249(C), and 252(C). If you have any questions, please call me at (509) 495-4706. Mike Fi Rate i\nal yst Enclosures Enclosures Copy: C. Ward (Potlatch) D. Peseau (Utility Resources, Inc) A. Yankel (Yankel & Assoc., Inc) CONFIDENTIAL ATTACHMENTS FILED AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: C1\SE NO: REQUESTER: TYPE: REQUEST NO. Idaho A VU-O4-01 / A VU-O4- IPUC Data Request 96B Supplemental D 1\ TE PREP 1\RED: WITNESS: RES PONDER: DEP AAT1\1ENT: TELEPHONE: 5/20/2004 Don Falkner Katherine Mitchell Rates (509) 495-4407 REQUEST: Please provide a report listing the amounts posted to account 1903 - Customer Records Collection Expenses for Gas Operations in 2000. Please include amount posted document number and date. Please also describe the events that resulted in an approximately 15% ($500,000) increase in those expenses over the 1999 amount. (Formerly 1\udit Request No. 89, dated on-site September 10, 2003). RESPONSE: 1\s noted in the company s initial response to this Data Request, the increase in Idaho Gas account 903 expense between 1999 and 2000 was approximately $139 000 and over half of the expenses in this account consist of labor and loadings. Preliminary analysis has not indicated any one material individual item that resulted in this increase. However, approximately $31 000 of the increase was due to increased benefit loadings. 1\dditionally, please refer to Witness Falkner s Exhibit No. 15, Page 8 of 8. It's important to note that during 1998 to 2002 average customers increased 18.18%. During this same time period, 1\ vista benefit loading rate increased from approximately 25% to 43.5%, also contributing to cost increases. While activity in individual FERC accounts may fluctuate in amount from year to year, the overall increase in O&M and 1\&G, excluding Depreciation and Taxes, on a per customer basis from 1998 to 2002, is 5.32%. VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: C1\SE NO: REQUESTER: TYPE: REQUEST NO. Idaho AVU-O4-01 / AVU-O4- IPUC Data Request Staff - 246 DATE PREPARED: WITNESS: . RESPONDER: DEP AAT1\1ENT: TELEPHO NE: 5/15/2004 Lafferty Lafferty Energy Resources (509) 495-4460 REQUEST: Were any reviews of the Boulder Park project s continued economic feasibility conducted after June 2001? If so, please provide:a. a copy of each analysisb. a summary of the results , andc. the detail of Company actions taken based upon those results. RESPONSE: The Company performed an assessment of a potential suspension of the Boulder Park project on August 9, 2001 due to cash flow concerns, which is attached. While an economic review compared to current market conditions was not performed at that time, the suspension assessment concluded that the Company was obligated to pay for approximately $22 million which represents a major portion of the total project cost at that time. Given the dollar commitment at the time of the suspension assessment, the decision was not to suspend the Boulder Park project. ~J="'ST Corp. DA TE: TO: FROM: SUBJECT: Interoffice Memorandum Energy Resources August 9 2001 Lloyd Meyers Jason Thackston Potential Cash Deferrals Associated with Suspension of Boulder Park or SIP Per your request, I worked with Tom Barker to estimate how much cash we could defer if we suspended construction of the Boulder Park and Spokane Industrial Park projects (Construction at Devil's Gap and Kettle Falls is complete - no cash savings available). . Boulder Park Most of the equipment has been ordered and is enroute to the site. If we were to delay the project and suspend all activity, we would be obligated to pay for most of the $23.million in project costs. The following costs might be delayed if the project is suspended: Building Installation Equipment Installation Commission Equipment Electrical Work Substation Work Other Storage for Materials and Equipment Received Total $ 200 000 550 000 150 000 000 000 200 000 300 000 (200 000) $ 2 200 000 Spokane Industrial Park This project is not as far along as Boulder Park, so there are opportunities to defer a more significant amount of cash payments on this project. Of the estimated $9.9 million in project costs, the following cost might be delayed if the project is suspended: Construction MgmtlEngineering Buildings Ventilation Sound Cens Exhaust Radiator Containment Air Compressor Misc Equipment Equipment Installation Commission Equipment Electrical Work Landscaping Site Grading Gas System Upgrades Substation Work Transmission/Distribution Work Communications System Work Storage for Materials and Equipment Received Total $ 360 000 650 ,000 250 000 150 000 220 000 1 0 000 80 I 000 300 000 250 000 000 500 ,000 000 000 100 000 200 000 000 000 (50 000) $ 3 225 000 Summary These are estimates that could vary widely either way. If the projects were both suspended today, we estimate a total cash obligation of $27.7 million will have been paid or accrued, while an additional $5.4 million would be deferred until the projects are reinstated. Ow- -h L-tL-f.!A +tfJ"0S' f S(p pro It\.~e:P.~,'1 ~~~, ha~ Jfi Page 2 JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO. REQUEST: VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION Idaho AVU-O4-01 / AVU-O4- IPUC Data Request Staff - 247 DATE PREP 1\RED: WITNESS: RESPONDER: DEP 1\RTMENT: TELEPHONE: 5/15/2004 Lafferty Lafferty Energy Resources (509) 495-4460 Were any changes made to the Boulder Park project based upon the economic reviews performed? If so, please provide a detailed description of those changes including costs that may have been reduced to improve the economics of the project. RESPONSE: No. VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: C1\SE NO: REQUESTER: TYPE: REQUEST NO. Idaho A VU-O4-01 / A VU-O4- IPUC Data Request Staff - 248 DATE PREPARED: WITNESS: . RESPONDER: D EP AR TMENT: TELEPHONE : 5/11/2004 Lafferty Lafferty Energy Resources (509) 495-4460 REQUEST: Please provide a detailed analysis of the costs that exceeded the June 2001 estimated project cost of $23.7 million. Include within your response: the reason for the costs, the amount of the costs any project reports or other documents discussing these costs, and an accounting/plant report that includes the transaction detail (amount posted date posted, work order number, vendor description , transaction description, and document number) for the project costs exceeding the estimated project cost of $23.7 million. RESPONSE: Attached is a spreadsheet summarizing the Boulder Park project cost components and comparing the approximate actual cost components totaling $32 million to the project costs of $23.7 million as of July 17, 2001. 1\ccompanying the cost comparison spreadsheet is a narrative discussion of the reasons for the major project cost component variances. Also attached is a sheet labeled Boulder Park Generating Station CAR data-backup 2-02" which provides an assessment of project costs and variances projected at that time compared to the original project cost estimate. The excess costs for the Boulder Park project generally stemmed from the fast track design-build approach that the Company chose in order to bring small generation on line as quickly as practical in order to mitigate the high prices and volatility in the electric power market during the energy crisis. Although not new technology for the power industry, the natural gas fired Response to Staff Request No. 349 Page 2 reciprocating engine-generators were the first project of its kind for A vista, which contributed in part to actual construction costs being higher than the original estimate. 1\lso attached is an internal audit summary of certain Boulder Park Generating Units contractor costs as of 10/10/02. Those materials are being provided with Avista s data response to Staff Request No. 248(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information and are separately filed under illi\PA 31.01.01 , Rule 067 , and Section 9-340D, Idaho Code. Summary of Costs Boulder Park Generating Station Part I - Wartsila Costs 17 est.actual difference Wartsila Recipricating Engine/Generators (Units 1 - 6)13,300,000 13,300,000 Change orders 208,000 208,000 Wartsila Subtotal 300 000 508 000 208,000 Part II - Contractor Construction Costs Construction Management (KBI)960 000 159,000 199 000 Buildings and Sound Enclosures (Furnish and Install)1 ,250,000 228,000 978,000 Ventilation/Exhaust/Duct System (fabricate & install)1 ,170,000 299,000 129,000 Mechanical equipment Installation and commissioning 130,000 712 000 1 ,582 000 Electrical equipment Installation and commissioning 720,000 546,000 826,000 Contract Construction Subtota 230 000 944 000 4, 714 000 Part III - Avista Construction Costs Site Work 220,000 410,000 190,000 Gas System 160,000 103,000 (57 000) S u bsta ti onfT ransmi ss i on/D istri buti on/Commu n cation 1 ,136,000 1 ,488,000 352 000 Permits/Property Acquisition/Legal Fees 450,000 280 000 (170,000) Miscellaneous Items Fire Detection & Suppression Systems 237 000 237 000 Electrical and mechanical systems 415 000 415,000 Emission Testing 000 35,000 Spare Parts and Tools 100 000 100 000 Avista Commissioning/Management/Engineering 110,000 110 000 vista Subtotal 966 000 178 000 212,000 Subtotal (Wartsila, Contractor, and Avista)21,496,000 28,630 000 134,000 Washington State Sales Tax (8.1 %)1 ,772 546 080,000 307,454 B&O Tax 000 000 AFUDC 387 286 300,000 912 714 TOTAL (Units 1 to 6)23,655,832 32,064 000 408,168 Boulder Park Generating Station Cost Summery Variance Details Part I - Wartsila The project had 13 Change orders issued for a total of $208 000. The major cost increase was $123 000 to cover the additional time Wartsila had to spend on the site over and above that which they contracted for. Part II - Contractor Construction Costs The total contractor construction cost over run was $4 714 000. This was primarily the extra cost associated with the following: a. Construction Management. The project took much longer than anticipated to complete thereby increasing the construction management costs by approximately $600 000 for supervision labor and $400,000 for additional purchasing and construction markups on the overruns on materials and subcontractors. Change orders for engineering changes totaled approximately $200,000. Total overrun from estimate is $1 199 000.b. Buildings and Sound Enclosures. The original estimate did not include the consumables building ($150,000), special inspections ($80,000), nor control room building ($500,000). The original building estimate from the consultant was lower than the actual cost by $400 000. The sound enclosures overran $60 000 due to design changes. The total overrun on buildings was $978 000.c. Ventilation/Exhaust/Duct systems. Change orders to add ventilation air louvers and piping/sheeting changes added $129,000 total. d. Mechanical equipment installation and commissioning. This was the single largest overrun on the project. The mechanical piping work ran $977,000 over due to the complexity of the piping as required versus the simple piping runs as bid from the minimal design prints. The exhaust stack was not in the original design and added $200 000. The exhaust duct insulation was not known in the original design and added $195,000. The foundation work associated with the auxiliary work outside the main building was not in the original estimate due to unknowns and underestimates of what was actually needed thereby adding $275 000. Commissioning costs were less here than estimated but resulted in increased A vista commissioning costs in Part TII. Total cost overrun here was $1 582 000.e. Electrical equipment installation and commissioning. The total overrun was $826 000. This was due to additions to the scope of work (ie. fire detection system) as well as the lack of electrical design especially in the control wiring. Part III - A vista Construction Costs The total A vista construction cost over run was $2 212 000. This was primarily the extra cost associated with the following: a. Site work. Road work was larger and more difficult than expected because Spokane County required a 24' road instead of a 20' road ($35,000). Site work was larger and more difficult than expected due to rocks, larger footprint of buildings and auxiliaries, as well as fire and water system increases ($130 000). The fence work was overlooked in original estimate ($25,000). Total overrun here was $190,000. b. Gas system. Relocating the station further east shortened the gas run and was $57,000 less than estimated.c. SubstationlTransmissionlDistribution/Communication systems. The substation transformer was more expensive than expected, the substation work was more extensive, but the transmission/distribution work was not as extensive as predicted for a total overrun of $220 000. The communication system was far more extensive and complicated than originally anticipated due to microwave not feasible and fiberoptic being required to handle the load thereby costing an additional $132 000.d. Permits/Property/Legal. The land was $150 000 less than expected and the legal was $20,000 less than expected for a cost underrun of $170 000.e. Miscellaneous. These were not included in the original estimate. The fire detection and suppression systems were $237,000; electrical and mechanical system work was $415,000 (broken down to control systems (g) $160 000; larger power cables and terminations (g) $35 000; extra grounding inside station (g) $20,000; work platforms (g) $150 000; handicap access ramp (g)$50 000); emission testing was $35,000; spare parts and tools was $100 000; and the 1\vista commissioning/management/engineering was $1,110 000. The extra labor costs were due to the fact that to get this project completed, 1\ vista essentially took over from the construction management firm the commissioning and final engineering. Taxes - The extra sales tax was from the increase in the cost of the project. The B&O taxes were not included in the original estimate. The extra AFUDC was accrued due to the extra time the project took to complete. Boulder Park Generation Station CAR data-backup 2- Major Changes from original handwritten CAA form: Original estimate = $23. Est. 1-30-02 $31. $ 8.0M required to complete project. Major changes in scope of work: ' .. Extra time on project for Wartsila, KBI, contractors, and 1\ vista construction personnel Extra i\FUDC accumulated due to increase in length of construction process Control building size increased 25% Handicapped access required by Spokane County Complete cooling system containment and oil system containment required by Spokane County Air Handling system added to achieve cooling and charge air requirements Extra catalyst required to achieve acrilyn and formaldehyde limits for SCi\PA Quieter radiator fans and silencers from Wartsila to meet sound limits Additional piping required to handle unforeseen complexity of mechanical systems Additional electrical work to handle unforeseen complexity of electrical systems(especially control systems) Road building changed from 14' driveway to 24' road complete with paving to satisfy Spokane County requirements /plus extra rock problems encountered Site grading size increased 20%/ extra rock problems encountered Added 115 Kv transmission line work Increases in Washington State Sales Tax and B&O tax Estimated total increase for above section = $5 ,.. 7 M Major portions of work not included in original estimate; Communication system to tie plant into remote operating facility Work platforms and cell hoists Fire & gas detection system Fire suppression system 10" fire line and hydrants/ " water line Remote and air handling computer control systems Security system Annunciator system Interior painting and insulation 4/0 power cable & terminations emergency shutdown generator and connections interior building grounding system emission testing Commissioning (1\ vista labor) Operations training for 1\ vista personnel . A vista Management and Engineering time Estimated total increase for above section = $2.3 M JURISDICTION: C1\SE NO: REQUESTER: TYPE: REQUEST NO. Idaho A VU - E-04-0 1 / A VU -04-0 1 IPUC Data Request Staff - 249 VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION 5/17/2004 Lafferty Lafferty Energy Resources (509) 495-4460 D1\TE PREPARED: WITNESS: RESPOND ER: DEP AA TMENT: TELEPHONE: REQUEST: Please provide a detailed description of the reasons for the delay in Boulder Park becoming operational. Please include in your response any project reports, memorandums, e-mails, or other documents that relate to the project's delayed completion. RESPONSE: In addition to the description already provided in Pre-filed Direct Testimony of witness Robert Lafferty, the following provides additional infonnation concerning Boulder Park project timeline delays. The initial schedule for installation of the six reciprocating engine-generator units was based upon design and construction concepts provided by the engine-generator manufacturer, incorporated extensive use of overtime labor and included an accelerated shipment schedule based on airfreight of the engine-generator units from the manufacturer in Europe. As forward power prices declined through the summer of 200 1 , plans for use of airfreight shipment of engine-generator units and the extensive use of overtime construction labor were dropped. These changes extended the project completion by at least an estimated 8 weeks. Construction pennits and associated air pennit processes took longer than anticipated. The main building construction pennit was not issued until early August 2001 and caused a delay to project construction start date adding approximately 4 weeks to the project timeline. addition, the associated pennit for construction of emission control facilities and other facilities exterior to the main building (i.e. exhaust and radiator piping systems) was not granted until the end of September 2001 thereby delaying start of construction on exterior systems until October. This resulted in an estimated additional 4 weeks of delay. Pennitting issues therefore resulted in approximately 8 weeks of delay time. Design changes were made as a result of the pennit requirements resulting in additional time and costs for engineering, construction and equipment. Examples included double wall Response to Staff Request No. 249 Page 2 radiator piping, radiator spill containment system, additional emission equipment and testing, and sound abatement enclosures. Additional design changes were required in order to add an air handling system to draw in cooler combustion air during periods of high ambient temperature. In addition, the engine-generator manufacturer required systems to be checked and cleaned several times prior to initiating testing. The additional design and construction associated with these items delayed completion by approximately 6 weeks. Pre-commissioning problem solving (i.e. engine crankshaft alignment, debris in the high pressure tanks, and insulation design) added approximately 4 weeks to the project completion schedule. During the commissioning process for the engine-generator units, complex control and software problems required solutions that required coordination with the European manufacturer technical support staff. Due to control wiring termination problems and difficulties in dealing with the manufacturer s proprietary control system software approximately 6 weeks was added to the project completion timeline. In total, the factors described added approximately 32 weeks to the Boulder Park project completion schedule. The excess costs for the Boulder Park project generally stemmed from the fast track design-build approach that the Company chose in order to bring small generation on line as quickly as practical in order to mitigate the high prices and volatility in the electric power market during the energy crisis. Although not new technology for the power industry, the natural gas fired reciprocating engine- generators were the first project of its kind for A vista, which contributed in part to actual construction costs being higher than the original estimate. Copies of memos and e-mails that relate to the delay in the project's completion are being provided with Avista s data response to Staff, Request No. 249(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information and are separately filed under IDAPA 31.01.01 , Rule 067, and Section 9-340D, Idaho Code. VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO. Idaho AVU-04-01 / AVU-04- IPUC Data Request Staff - 250 DATE PREPARED: WITNES S RESPONDER: DEP ARTMENT: TELEPHONE: 5/18/2004 Lafferty Lafferty Energy Resources (509) 495-4460 REQUEST: Were any reviews of the Kettle Falls project's continued economic feasibility conducted after September 2001 using forward price information as of the date of the review? If so, please provide: a copy of each analysis a summary of the results, and the detail of Company actions taken based upon those results. RESPONSE: Further economic feasibility studies were not conducted after September 2001. Commitments had been made to major project equipment at that point in time. 1\t the time of the September 12, 2001 analysis, which is included in witness Robert Lafferty Exhibit 9, Schedule 36, the Company decided to delay the construction schedule for the Kettle Falls project to move the projected start-up date from April 2002 to July 2002. The reason for this change was because forward power prices for the second quarter time period were projected to be relatively low and studies showed little or no value to the project being on line in second quarter 2002. An e-mail is attached describing this decision. ::;.' ' roce . . rom: Sent: To: Cc: Subject: Meyers, Lloyd Friday, September 14, 2001 8:41 AM Wenke, Steve; Parmentier, Jerry Kalich, Clint; Lafferty, Bob; Groce, Ed; Gorton, Pat; Norwood, Kelly; Warne, Sandee; Morris, Scott; Peterson, Ron Kettle Falls CT I asked Clint Kalich to review the economics of proceeding with the Kettle Falls CT. His study and memo to me dated September 12, 2001 , show the gas turbine and steam generator to have a Net Present Value of nearly $4 million over the life of the project. For the first 6 years, projected cash flow averages a negative $90 000 annually before becomingpositive in year 7 and all subsequent years. The September 12 study reflects current forward power and natural gas prices. We have no way of knowing if forward prices will go up or down from today s estimates. If power prices go up, the project becomes more economic, if down theproject is less economic. What we know is that prices can go up much more than they can go down. For example, in ayear that the forward price is $40/mwh , future forward prices for the same year could drop some, in the extreme into the high teens, but could exceed $40 by several times even with price caps imposed. The decision to start or stop a project can be made in a very short amount of time. Construction on a project can be stopped in a short amount of time. But it take time from the decision to start to finish a project. Because the project is economic with todays projected prices and the economic risk of prices going up is greater than the risk of prices going down, the project will not be terminated. However, the current schedule calls for start-up in April 2002. Power prices typically are relatively low in April, May and June. Our studies show little or no value to the project being on line in these months. For this reason we will delay the Commercial Operation date to July and adjust the construction schedule accordingly. Gary Ely has reviewed this change and approved it. Please make sure that all studies, budgets, etc. reflect the new start date and resulting cash flow requirements. VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO. Idaho A VU-O4-01 / A VU-04- IPUC Data Request Staff - 251 DATE PREP i\RED: WITNESS: RESPONDER: D EP AR TMENT: TELEPHONE: 5/18/2004 Lafferty Lafferty Energy Resources (509) 495-4460 REQUEST: Were any changes made to the Kettle Falls project based upon the economic reviews performed? If so, please provide a detailed description of those changes including costs that may have been reduced to improve the economics of the project. RESPONSE: Not applicable. The requested materials are being provided with Avista s data response to Staff, Request No. 246(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information and are separately filed under IDi\PA 31.01.01 , Rule 067, and Section 9-340D, Idaho Code. VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQ DES TER: TYPE: REQUEST NO. Idaho AVU-O4-01 / AVU-04- IPUC Data Request Staff - 252 DATE PREP 1\RED: WITNES S , RESPONDER: DEP 1\RTMENT: TELEPHONE: 5/19/2004 Lafferty Lafferty Energy Resources (509) 495-4460 REQUEST: Please provide a detailed analysis of the costs that exceeded the estimated project costs of $8. million. Include within your response: the reason for the costs, the amount of the costs, any project reports or other documents discussing these costs , and an accounting/plant report that includes the transaction detail (amount posted, date posted, work order number, vendor description, transaction description, and document number) for the project costs exceeding the estimated project cost of $8.5 million. RESPONSE: The requested materials are being provided with A vista s data response to Staff, Request No. 252(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067, and Section 9-340D, Idaho Code. JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO. REQUEST: VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION Idaho AVU-04-01 / AVU-04- IPUC Data Request Staff - 253 DATE PREPARED: WITNESS: RESPONDER: DEPARTMENT: TELEPHONE: 5/11/2004 Lafferty Lafferty Energy Resources (509) 495-4460 Please provide a detailed description of the reasons for the delay in Kettle Falls becoming operational. Please include in your response any project reports, memorandums, e-mails, or other documents that relate to the project's delayed completion. RESPONSE: Please see response to Staff Data Request No. 250. VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: C1\SE NO: REQUESTER: TYPE: REQUEST NO. Idaho A VU-O4-01 / A VU-O4- IPUC Data Request Staff - 262 D1\TE PREPi\RED: WITNESS: , RESPONDER: DEP AATMENT: TELEPHONE: 05/17/2004 Don Falkner Kelly Irvine Resource 1\ccounting (509) 495-4335 REQUEST: What expenses for the Plymouth LNG facility are included in the Company s filing? Please identify, on a system basis and an Idaho jurisdictional basis, and by FERC account, all expenses associated with the Plymouth LNG facility. Specifically include capacity and deliverability expenses. RESPONSE: For the year 2002, 1\vista paid Northwest Pipeline $394 567 for capacity and deliverability from the Plymouth LNG facility for Washington and Idaho. Idaho s allocated portion is $104 087. These costs are expensed in FERC account 804. VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: C1\SE NO: REQUESTER: TYPE: REQUEST NO. Idaho A VU-O4-01 / A VU-O4- IPUC Data Request Staff - 263 D1\ TE PREPARED: WITNESS: RESPOND ER: DEP AATMENT: TELEPHONE: 05/17/2004 Don Falkner Kelly Irvine Resource 1\ccounting (509) 495-4335 REQUEST: What amounts for the Plymouth LNG facility are included in rate base in the Company s filing, other than Company 1\djustment E, Gas Inventory 1\djustment. Please identify, on a system basis and an Idaho jurisdictional basis, and by FERC account, all amounts included in rate base associated with the Plymouth LNG facility. RESPONSE: There are no costs included in rate base for the Plymouth LNG facility in the Company s filing other than Company 1\djustment E, Gas Inventory 1\djustment. 1\1l costs for the Plymouth LNG facility are related to capacity and deliverability as detailed in Staff Request No. 262. VISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: Ci\SE NO: REQUESTER: TYPE: REQUEST NO. Idaho A VU - E-O4-0 1 / A VU -O4-0 1 IPUC Data Request Staff - 264 Di\ TE PREPARED: WITNESS: RESPOND ER: D EP AA TMENT: TELEPHONE: 05/17/2004 Kelly Irvine Resource i\ccounting (509) 495-4335 REQUEST: Please provide a schedule showing any injections or withdrawals to the Plymouth LNG facility since January 1 , 1989. Please provide the information by month and year, showing the amount inj ected and amount withdrawn. RESPONSE: Company records for the Plymouth facility only go back to 1998. The following list shows the facilities utilization from that year forward. 'FACILITY NAME 1100607 AVA Sum of DLVRD AMT RAN TYPE INJECTION DATE 05-28-1999 07-01-199 07-02-1999 07-03-1999 07 -04-1999 07 -05-1999 07-06-1999 07-07-199 07-08-1999 07 -09-1999 07-10-1999 07-11-199 07-12-1999 07-13-1999 07-14-1999 07-15-1999 07-16-1999 07-17-1999 07-18-1999 07-19-1999 07-20-1999 07-21-1999 07 -22 -1999 07-23-1999 116 1993 1164 996 996 996 136 124 07 -24-1999 07-25-199 07-26-199 07-27-199 07-28-199 07-29-199 07 -30-199 07-31-1999 08-01-1999 08-02-1999 08-03-199 08-04-1999 08-05-1999 08-06-199 08-07 -199 08-08-1999 08-09-999 08-1 0-1.999 08-11-199 08-12-199 08-13-1999 08-14-1999 08-15-1999 08-16-199 08-17-1999 08-18-1999 08-19-1999 08-20-1999 08-21-1999 08-22-199 08-23-1999 08-24-199 08-25-1999 08-26-1999 08-27 -199 08-28-1999 08-29-199 08-30-199 08-31-199 09-04-1999 09-05-1999 09-06-999 09-07-1999 09-08-1999 09-09-999 09-1 0-1999 09-11-1999 09-12-1999 09-13-1999 09-14-1999 09-15-1999 09-18-1999 09-19-1999 Response to Staff Request No. 264 Page 2 996 138 1381 1381 142 774 1358 297 2288 2288 297 477 1086 837 836 09-20-1999 09-26-1999 09-27 -199 1 0-09-199 10-10-1999 1 0-11-1 99 10-12-199 10-16-199 10-17-199 10-18-199 11-06-199 11-07-1999 11-08-1999 03-06-2001 03-07-2001 03-08-2001 03-09-2001 03-10-2001 03-11-2001 ' 03-12-2001 03-13-2001 03-14-2001 03-15-2001 03-20-2001 03-22-2001 03-23-2001 03-27-2001 06-01-2002 06-02-2002 06-03-2002 06-04-2002 06-05-2002 06-06-2002 06-07 -2002 06-08-2002 06-09-2002 06-10-2002 06-11-2002 06-12-200 06-13-2002 06-14-2002 06-15-2002 06-16-2002 06-17 -2002 06-18-2002 06-19-2002 06-20-2002 06-21-2002 06-22-2002 06-23-2002 06-24-2002 06-25-2002 06-26-2002 Response to Staff Request No. 264 Page 3 198 198 198 196 882 827 198 1983 1983 1155 1532 1044 7571 12499 12556 12578 1214 573 513 118 853 8537 8894 4953 4953 4953 4953 4953 4953 309 4953 4953 4953 4953 4952 4953 4953 4953 4953 4953 4953 4411 2476 2434 2434 2434 247 2476 06-27 -2002 06-28-2002 06-29-2002 06-30-2002 07-01-2002 07 -02-2002 07 -03-2002 04-04-200 04-05-200 04-06-200 04-07 -200 04-08-200 04-09-2003 04-10-2003 04-11-200 04-12-200 04-13-200 04-14-2003 04-15-2003 04-16-2003 04-17 -2003 04-18-2003 04-19-200 04-20-2003 04-21-200 04-22-2003 04-23-2003 04-24-200 04-25-200 04-26-2003 04-27 -2003 04-28-200 04-29-2003 04-30-2003 05-01-2003 05-02-2003 05-03-2003 05-04-2003 05-05-2003 05-06-2003 05-07 -2003 05-08-2003 05-09-2003 05-10-2003 05-11-2003 05-12-2003 05-13-2003 05-14-2003 05-15-2003 05-16-2003 05-17-2003 05-18-2003 05-19-2003 Response to Staff Request No. 264 Page 4 Response to Staff Request No. 264 Page 5 05-20-200 05-21-200 05-22-2003 05-23-2003 05-30-2003 05-31-200 INJECTION Total 50008 ITHDRAWAL 12-20-1998 2200 12-21-1998 2200 12-22-1998 2200 12-23-1998 1000 12-24-199 22000 12-25-1998 12-26-1998 12-27-1998 12-28-1998 12-29-1998 02-08-200 01-15-2001 14678 01-16-2001 5061 01-18-2001 01-24-2001 607 01-25-2001 750 01-26-2001 7500 01-27-2001 7592 01-28-2001 0000 02-08-2001 10122 02-09-2001 16049 02-10-2001 104 02-11-2001 104 02-12-2001 104 02-13-2001 1380 02-14-2001 7333 02-26-2001 2049 02-01-2002 14451 02-13-2002 22000 02-24-2002 2200 02-25-2002 2200 02-26-2002 907 03-06-2002 1220 03-13-2002 4000 03-20-2002 22000 03-21-2002 04-07 -2002 1015 02-25-200 2200 02-26-2003 22000 02-27 -2003 22000 02-28-2003 2200 03-01-2003 1100 03-02-2003 11 000 03-03-2003 11000 03-04-2003 11 000 03-05-2003 ITHDRAWAL Total Grand Total Response to Staff Request No. 264 Page 6 03-06-2003 03-07 -2003 03-05-200 03-06-200 03-07 -200 03-08-200