20130716Staff 1-10 to IPC.pdf

KRISTFNE A.SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PU BOX $3720
BOISE,IDAHO 83720-0074
[phone]
BARNO.661$
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-5918
Attorney for the Commission Staff
?13]UL 1 H 9:31
!‘Itç Cr;—I L.1
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER Of IDAHO POWER
COMPANY’S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR INVESTMENT IN
SELECTIVE CATALYTIC REDUCTION
CONTROLS ON JIM BRIDGER UNITS 3 AND 4.
)
)CASE NO.IPC-E-13-16
)
)FIRST PRODUCTION
REQUEST OF THE
)COMMISSION STAFF TO
)IDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Kristine A.Sasser.Deputy Attorney General,requests that Idaho Power Company (Company)
provide the following documents and information on or before TUESDAY,AUGUST 6,2013.
This Production Request is to be considered as continuing,and Idaho Power Company is
requested to provide,by way of supplementary responses,additional documents that it or any person
acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question and any supporting workpapers that provide detail or
are the source of information used in calculations.The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person preparing
the document,and the name,location and phone number of the record holder and,if different,the
witness who can sponsor the answer at hearing.Reference IDAPA 3 1.01.01.228.
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 16,2013
REQUEST NO.1:Please provide a cost breakdown of the entire Jim Bridger Units 3 and 4
Environmental Compliance upgrade project that makes up the Commitment Estimate.Please include
a narrative or description for each element of cost.Also,please provide a copy of the Engineering,
Procurement and Construction (EPC)contract including all cost estimates,timelines for completion,
etc.
REQUEST NO.2:Please provide an itemized estimate of additional costs if the Company
delays the start of the project until November 21,2013,but is still required to meet the Wyoming
State Implementation Plan (SIP)deadlines for compliance.
REQUEST NO.3:Please provide a three-year history by month of unit availability and
amount of generation for Jim Bridger Units 3 and 4.
REQUEST NO.4:Please provide an itemized estimate of costs and benefits for each
alternative (i.e.,emission control upgrade,gas conversion,CCCT replacement),a short description of
each element of cost/benefit,the timing of each element of cost/benefit (e.g.,gas conversion capital
cost,mine remediation cost,CCCT capital investment,etc.),and whether each is a one-time
cost/benefit or is re-occurring.
REQUEST NO.5:Please provide the cost of transmission investment that could be
realistically avoided or delayed if Jim Bridger Units 3 or 4 (or both)were shut down on the Wyoming
SIP compliance dates and alternative generation sources were installed close to major load centers.
REQUEST NO.6:Please provide the reduction in capacity for Jim Bridger Units 3 and 4 if
the Environmental Protection Agency (EPA)places a 0.05 lbs/MMBTU compliance standard for
nitrogen oxide at some future date.What are the incremental costs (i.e.capital,maintenance,and
operation)associated with the more stringent standard on each unit?
REQUEST NO.7:Please provide a copy of the Request for Proposal (RFP)and RFP
evaluation results for the EPC contractor.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 16,2013
REQUEST NO.8:Please discuss Idaho Power’s course of action and the ramifications of
those actions if the EPA doesn’t finalize its rules by the final Notice to Proceed deadline (see the
direct testimony of Michael Youngblood,pg 18).
REQUEST NO.9:Please provide an explanation of the contractual obligations and costs
between Idaho Power and PacifiCorp if Idaho Power were to decide to abandon generation at Jim
Bridger on the Wyoming SIP compliance dates for each unit.Please provide documentation that
supports these obligations and costs.
REQUEST NO.10:Please provide the dates when the useful life of Jim Bridger Units 3 and
4 ends.
Dated at Boise,Idaho,this jday of July 2013.
,2
Krige A.Sasser
Deputy Attorney General
Technical Staff:Mike Louis
i:umisc:prodreq/ipce 13.1 6ksrrnl prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JULY 16,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF JULY 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMiSSION STAFF TO IDAHO POWER,IN CASE NO.IPC-E-13-16.BY
MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
LISA D NORDSTROM
JENNIFER REINHARDT
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
E-MAIL:I nordstrorn@i dahopower.corn
ireinhardt)idahopower.corn
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE