20130821Staff 25-44 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
BAR NO. 6618
Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
llf i tr:a.ll t-" .)..t1i:'l ri:.l i:-. I i:i /--..J1
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)) CASE NO. rPC-E-13-r6
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR INVESTMENT IN ) THIRD PRODUCTION
SELECTIVE CATALYTIC REDUCTION ) REQUEST OF THE
CONTROLS ON JIM BRTDGER UNITS 3 AND 4. ) COMMTSSTON 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 (Idaho Power;
Company) provide the following documents and information for Request Nos. 25 - 38 on or
before WEDNESDAY, SEPTEMBER 4, 2013, and Request Nos. 39 - 44 on or before
WEDNESDAY, SEPTEMBER 11, 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 and Procedure must include the name and phone
number of the person preparing the document, and the name, location and phone number of the
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF AUGUST 2I,2OI3
record holder and, if different, the witness who can sponsor the answer at hearing. Reference
rDAPA 3t.01.0t.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.
REQUEST NO. 25: Please provide a list of any new facility investments subject to this
filing that will be shared between any of the Jim Bridger generation units. If a facility is shared,
please provide the total cost of the facility (broken down by capital, operation, or maintenance)
and a percentage ofcost allocated to each unit.
REQUEST NO. 26: Please provide a copy of all the worksheets (with all formulas
intact) used to develop the SAIC "static" analysis including: all the output, operational forecasts,
input data, and assumptions.
REQUEST NO. 27: Please explain why Idaho Power applied a Sumas basis, rather than
a Rockies or AECO basis to develop its natural gas forecast for the Coal Unit Environmental
Investment Analysis. Please provide the Sumas differentials and the Henry's Hub forecast that
were used to develop the natural gas forecast.
REQUEST NO.28: Please provide the cost assumptions and basis used to estimate
decommissioning costs for Jim Bridger Unit 3 and Unit 4 in the gas conversion and retire/replace
scenarios of the Coal Unit Environmental Investment Analysis. Please provide a cost breakdown
by generating unit and timing of costs.
REQUEST NO.29: Was the sale of the Bridger Coal Company mining operation
considered in the gas conversion and retire/replace scenarios of the Coal Unit Environmental
Investment Analysis? Hypothetically, what would the Company estimate as its market value at
the end of years 2015 and 2016 as share of the coal no longer used for Units 3 and 4?
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF AUGUST 2I,2OI3
REQUEST NO. 30: Did the Company adjust its natural gas price forecast based on
different CO2 prices by assuming that natural gas prices and CO2 prices are positively correlated
in its Coal Unit Environmental Investment Analysis?
REQUEST NO. 31: Please describe the method and factors used to develop the
projected generation forecast contained in Table A-26 inthe SAIC study. Please provide all
worksheets used to derive them with all formulas intact.
REQUEST NO.32: Referring to Idaho Power's response to Staff Production Request
No. 1, please provide a cost breakdown of all individual items listed in the Development Phase
cost category (Permitting, Wyoming and Utah docket proceeding cost, completion of design
basis and project concept studies, baseline performance testing, etc.). Please show the cost for
each generation unit (Jim Bridger Unit 3 and Unit 4) and by actual vs. remaining forecast. For
forecasted items, please provide the basis/method for developing the estimate (i.e., actual quotes,
contracts, historical comparable cost, etc.) and all documents and worksheets (with formulas
intact) used to develop the estimate.
REQUEST NO.33: Referring to Idaho Power's response to Staff Production Request
No. 1, please provide the basis/method for developing the Boiler and Air Preheater
Reinforcement Work estimate (i.e., actual quotes, contracts, historical comparable cost, etc.) and
all documents and worksheets (with formulas intact) used to develop the estimate.
REQUEST NO.34: Referring to Idaho Power's response to Staff Production Request
No. 1, please provide the basis/method for developing the Economizer Upgrade estimate (i.e.,
actual quotes, contracts, historical comparable cost, etc.) and all documents and worksheets (with
formulas intact) used to develop the estimate.
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF AUGUST 2I,2OI3
REQUEST NO.35: Referring to Idaho Power's response to Staff Production Request
No. l, please provide the basis/method for developing the Low Temp Economizer Control
System estimate (i.e., actual quotes, contracts, historical comparable cost, etc.) and all documents
and worksheets (with formulas intact) used to develop the estimate.
REQUEST NO. 36: Referring to Idaho Power's response to Staff Production Request
No. 1, please provide the basis/method for developing the Flue Gas Reinforcement estimate (i.e.,
actual quotes, contracts, historical comparable cost, etc.) and all documents and worksheets (with
formulas intact) used to develop the estimate.
REQUEST NO.37: Refening to Idaho Power's response to Staff Production Request
No. 1, please provide the basis/method for developing the Spare Parts Allowance estimate (i.e.,
actual quotes, contracts, historical comparable cost, etc.) and all documents and worksheets (with
formulas intact) used to develop the estimate.
REQUEST NO.38: Referring to Idaho Power's response to Staff Production Request
No. 1, please provide a cost breakdown of all individual items listed in the Other Cost category
(PacifiCorp's engineer performance requested work through the project implementation phase,
initial fills of lubricants and ammonia reagent, etc.) by the cost for each generation unit (Jim
Bridger Unit 3 and Unit 4). Please provide the basisimethod for developing the category
estimate (i.e., actual quotes, contracts, historical comparable cost, etc.) and all documents and
worksheets (with formulas intact) used to develop the estimate.
REQUEST NO.39: Please explain how cost estimates for mercury controls (MATs),
Clean Water Act compliance, and Coal Combustion Residual compliance used in the Coal Unit
Investment Analysis were derived and explain what means (benchmarks, price quotes, etc.) were
used to ensure accuracy.
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF AUGUST 27,2013
REQUEST NO. 40: Please provide the Request for Proposal (RFP), competitive
bidding documentation, and RFP evaluation results used to select the static coal study consultant
(sArc).
REQUEST NO. 41: Please provide the basis and assumptions used to estimate
transportation costs to arrive at an Idaho city-gate price used to develop the natural gas forecast
for the Coal Unit Environmental Investment Analysis.
REQUEST NO. 42: How close is Idaho Power to the two million gallon per dayl25
percent withdrawal for cooling purpose limit proposed in 3 16(b) of the federal Clean Water Act?
Please base your answer on historical usage compared to the standard.
REQUEST NO. 43: Please provide the amount carbon prices would need to increase on
an average percentage basis (from the base planning CO2 prices) to make the emission control
upgrade option uneconomic in terms of total portfolio cost expressed in net present value when
compared to gas conversion and Combined Cycle Combustion Turbine (CCCT) replacement
alternative cases using base planning assumptions for all other variables.
REQUEST NO. 44: Please provide the amount natural gas prices would need to
decrease on an a'verage percentage basis (from the base planning natural gas price) to make the
emission control upgrade option uneconomic in terms of total portfolio cost expressed in net
present value when compared to gas conversion and CCCT replacement alternative cases using
base planning assumptions for all other variables.
Dated at Boise, Idaho, tni, bl{day of August 2013.
Technical Staff: Mike Louisl2s - 44
i:umisc:prodreq/ipcel3.l6ksml prod req 3
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF
itine A. Sasser
Deputy Attorney General
AUGUST 27,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF AUGUST 2013,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-13-16, By
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
JENNIFER REINHARDT-TES SMER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
i reinhardt@ idahopower. com
[e-mail]
CBearry@idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS
515 N 27TH ST
BOISE ID 83616
E-MAIL: [e-mail]
gre g@richardsonadams. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
DEAN J MILLER
CHAS F McDEVITT
CELESTE K MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: [e-mail]
chase@mcdevitt-mil ler.com
ck@mcdevitt-miller. com
SECRETARY
CERTIFICATE OF SERVICE