Loading...
HomeMy WebLinkAbout20130827Staff 45-48 to IPC.pdfKRISTINE 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: 472W. WASHINGTON BOISE, IDAHO 83702-5918 Attomey for the Commission Staff a-:_ --. 1- : ili-i;:rtl '': i:.qoji. ii.i-l 1. I ;.il r.i'L;J BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF rDAHO POWER ) coMPANy'S APPLICATION FOR A ) CASE NO. IPC-E-13-16 CERTIFICATE OF PUBLIC CONVENIENCE ) AND NECESSITY FOR INVESTMENT IN ) FOURTH PRODUCTION SELECTIVE CATALYTIC REDUCTION ) REQUEST OF THE CONTROLS ON JIM BRTDGER UNrrS 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 on or before TUESDAY, SEPTEMBER 10, 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 FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF AUGUST 27,2013 record holder and, if different, the witness who can sponsor the answer at hearing. Reference IDAPA 31.01 .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. REQUEST NO. 45: Please explain why Sulfur Dioxide (SO2) emission levels for Jim Bridger Unit 4 are almost 300 times lower than the levels for Jim Bridger Unit 3 as shown in Table A-l in Tom Harvey's Exhibit No. 5. REQUEST NO. 46: In Tom Harvey's Exhibit No. 5 (page 3-8), it says "the study approach examined costs and benefits of each unit's upgrade or retirement decision separately," and that "...the effects of the given unit's scenario was isolated and considered no interaction with any other units on the IPC system." Because each analysis was isolated from the system, it would seem that if a generation unit does not require natural gas as fuel for a given scenario, that the price of natural gas would have no effect on the analysis results. Please explain why the Total Cost results for the Emission Upgrade Scenario for Jim Bridger Unit 3 (page 4-6) and Unit 4 (page 4-8) show increasing Total Net Present Value (NPV) costs with increasing natural gas prices for a given carbon price (i.e. carbon prices are held constant). REQUEST NO. 47: In Tom Harvey's Exhibit No. 5 (page 3-9), the Company and SAIC assumed that a price of carbon from burning natural gas would be 50 percent of the $/MWh price for coal. In the Natural Gas Conversion scenarios for Jim Bridger Units 3 and 4 in the low and planning gas cases, the Total NPV cost results for the high carbon cases are lower than the no carbon and planning carbon cases for a given natural gas price. Please explain why the high carbon cases reflect a higher total cost than the no carbon or planning carbon cases. REQUEST NO. 48: In response to Staffs Production Request No. 5, the Company states "there are no large future transmission investments between Jim Bridger and the Treasure Valley that can be avoided if Jim Bridger Units 3 and 4 were to be shut down." Per the original request, Staff requests whether or not transmission investments can possibly be avoided or FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF AUGUST 27,2013 Dated at Boise, Idaho, tfri, O,7traay of August 2013. Technical Staff: Mike Louisl45 - 48 "delayed." Please answer the question as it pertains to specifically whether or not investment in the Gateway or delayed. "delaying" potential investment and West transmission line could be avoided i:umisc:prodreq/ipcel3. I 6ksml prod req 4 FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF Deputy Attorney General AUGUST 27,2013 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF AUGUST 2013, SERVED THE FOREGOING FOURTH 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 ID 83707-0070 E-MAIL : lnordstrom@idahopower.com j reinhardt@idahopower. com dockets@ idahopower. com C Bearry@idahopower. com PETER J RICHARDSON GREGORY M ADAMS RICHARDSON ADAMS 515 N 27TH ST BOISE ID 83616 E-MAIL: peter@richardsonadams.com sres@.richardsonadams.com BENJAMIN J OTTO ID CONSERVATION LEAGUE 7IO N 6TH ST BOISE ID 83702 E-MAIL: botto@idahoconservation.ore KEN MILLER SNAKE RIVER ALLIANCE BOX 1731 BOISE ID 83701 E-MAIL: kmiller@snakeriveralliance.ors DR DON READINU 6070 HILL ROAD BOISE ID 83703 E-MAIL: dreadine@mindspring.com DEAN J MILLER CHAS F McDEVITT CELESTE K MILLER McDEVITT & MILLER LLP 420 W BANNOCK BOISE TD 83702 E-MAIL: joe@mcdevitt-miller.com chase@mcdevitt-mil ler. com ck@mcdevitt-miller. com CERTIFICATE OF SERVICE