HomeMy WebLinkAbout20130906IPC to Staff 25, 32, 34 and 36-39.pdfHO
PIER
An IDACORP Company
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JENNIFER M.REINHARDT-TESSMER
Corporate Counsel fT_I \jreinhardtcidahopower.com
September 6,2013
VIA HAND DELIVERY
Jean D.Jewell,Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise,Idaho 83702
Re:Case No.IPC-E-13-16
Certificate for Public Convenience and Necessity for Jim Bridger Units 3 and
4 —Idaho Power Company’s Second Response to the Third Production
Request of the Commission Staff
Dear Ms.Jewell:
Enclosed for filing in the above matter are an original and three (3)copies of Idaho
Power Company’s Second Response to the Third Production Request of the Commission
Staff (“Staff”)to Idaho Power Company.In addition,enclosed in a separate envelope are
an original and three (3)copies of Idaho Power Company’s Confidential Responses to
Request Nos.34 and 36-38 of the Third Production Request of the Commission Staff to
Idaho Power Company.
Also,enclosed are four (4)copies of a confidential disk containing information
responsive to Staff’s Third Production Request.Please handle the confidential information
in accordance with the Protective Agreement executed in this matter.
Sincerely,
J nnifer M.Reinhardt-Tessmer
J RT:csb
Enclosures
1221 W.Idaho St.(83702)
P.O.Box 70
Boise,ID 83707
LISA D.NORDSTROM (ISB No.5733)
JENNIFER M.REINHARDT-TESSMER (ISB No.7432)
Idaho Power Company
1221 West Idaho Street (83702)
P.O.Box 70
Boise,Idaho 83707
Telephone:(208)388-5825
Facsimile:(208)388-6936
lnordstromtidahopower.com
jreinhardtidahopower.com
2r13SE —‘3 P !2:hO
fH iHc’
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE INVESTMENT
IN SELECTIVE CATALYTIC REDUCTION
CONTROLS ON JIM BRIDGER UNITS 3
AND 4.
CASE NO.IPC-E-13-16
IDAHO POWER COMPANY’S
SECOND RESPONSE TO THE
THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY
COMES NOW,Idaho Power Company (“Idaho Power”),and in response to
Request Nos.25,32,34,and 36-39 of the Third Production Request of the Commission
Staff to Idaho Power Company dated August 21,2013,herewith submits the following
information:
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -1
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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 of cost allocated to each unit.
RESPONSE TO REQUEST NO.25:The anhydrous ammonia receiving depot
will be a common facility shared between Jim Bridger Units 3 and 4 only.Currently,
there is not a “breakout cost”from the Engineering,Procurement,and Construction
contract for the depot only.It is assumed that all associated initial capital,run-rate
capital,operational,and maintenance costs for this common facility will be shared
between Units 3 and 4 at a rate of 50 percent per each.
The response to this Request is sponsored by Tom Harvey,Joint Projects
Manager,Idaho Power Company.
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -2
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.
RESPONSE TO REQUEST NO.32:A breakdown of items listed in the
Development Phase Cost category is included in the Excel spreadsheet provided on the
confidential CD.The confidential CD will be provided to those parties that have
executed the Protective Agreement in this matter.
The expected costs identified in the confidential spreadsheet as “Forecast Costs
2013 —Jun-Dec”are assumed to be final,with the exception of possible unforeseen
adjustments or unidentified costs that may be incurred,since the development phase is
complete.
The response to this Request is sponsored by Tom Harvey,Joint Projects
Manager,Idaho Power Company.
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -3
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.
RESPONSE TO REQUEST NO.34:The response to this Request is
confidential and will be provided separately to those parties that have executed the
Protective Agreement in this mailer.
The response to this Request is sponsored by Tom Harvey,Joint Projects
Manager,Idaho Power Company.
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -4
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.
RESPONSE TO REQUEST NO.36:The response to this Request is
confidential and will be provided separately to those parties that have executed the
Protective Agreement in this mailer.
The response to this Request is sponsored by Tom Harvey,Joint Projects
Manager,Idaho Power Company.
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -5
REQUEST NO.37:Referring 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.
RESPONSE TO REQUEST NO.37:The response to this Request is
confidential and will be provided separately to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Tom Harvey,Joint Projects
Manager,Idaho Power Company.
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -6
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 Bridget Unit 3 and Unit 4).Please provide the
basis/method 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.
RESPONSE TO REQUEST NO.38:The response to this Request is
confidential and will be provided separately to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Tom Harvey,Joint Projects
Manager,Idaho Power Company.
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -7
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.
RESPONSE TO REQUEST NO.39:Please see below.
Mercury Controls.The capital estimates were based in part upon analysis
performed by Sargent &Lundy that assumed the Jim Bridger power plant was going to
use activated carbon and calcium bromide (“CaSt”)and potentially a scrubber re
emission chemical.After testing was completed in 2011,the estimates were refined to
include the assumption that the plant would only use CaSt and the scrubber re-emission
chemical.These refined numbers were derived in large part from budgetary quotes from
chemical suppliers as well as PacifiCorp’s corporate engineering’s estimate for project
management.The operations and maintenance numbers are based upon the testing
that was completed at the plant,mercury levels in the coal,and budgeted plant capacity
factors.
CCR Proiects.Pond project estimates are based upon studies completed by
Tetra Tech.Landfill projects are based upon scale-ups of actual landfill project costs at
the Huntington plant.
Clean Water Act 316(b)Proiects.This project estimate was developed by
PacifiCorp corporate environmental staff with guidance from Mid-America Electric
Holdings Company in estimating the costs associated with studies/intake structure
modifications necessary to comply with the final 316(b)rule.
The response to this Request is sponsored by Tom Harvey,Joint Projects
Manager,Idaho Power Company.
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -8
DATED at Boise,Idaho,this 6th day of September 2013.
JEN N I F
Afforne Idaho Power Company
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day of September 2013 I served a true and
correct copy of IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below,and
addressed to the following:
Commission Staff
____Hand
Delivered
Kristine A.Sasser
____U.S.
Mail
Deputy Attorney General
____Overnight
Mail
Idaho Public Utilities Commission
____FAX
472 West Washington (83702)X Email kris.sasser(puc.idaho.ciov
P.O.Box 83720
Boise,Idaho 83720-0074
Industrial Customers of Idaho Power
____Hand
Delivered
PeterJ.Richardson
____U.S.
Mail
Gregory M.Adams
____Overnight
Mail
RICHARDSON ADAMS,PLLC
___FAX
515 North 27th Street (83702)X Email peterrichardsonadams.com
P.O.Box 7218 qreq(richardsonadams.com
Boise,Idaho 83707
Dr.Don Reading
____Hand
Delivered
6070 Hill Road
____U.S.
Mail
Boise,Idaho 83703
____Overnight
Mail
____FAX
X Email dreadingmindspring.com
Idaho Conservation League
____Hand
Delivered
Benjamin J.Otto
____U.S.
Mail
Idaho Conservation League
____Overnight
Mail
710 North Sixth Street
____FAX
Boise,Idaho 83702 X Email botto(idahoconservation.orq
Snake River Alliance
____Hand
Delivered
Dean J.Miller
____U.S.
Mail
McDEVIU &MILLER LLP
____Overnight
Mail
420 West Bannock Street
____FAX
P.O.Box 2564 X Email joemcdevitt-miller.com
Boise,Idaho 83701
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -10
Ken Miller,Clean Energy Program Director
____Hand
Delivered
Snake River Alliance
____U.S.
Mail
P.O.Box 1731
____Overnight
Mail
Boise,Idaho 83701 FAX
X Email kmillersnakeriveralliance.orq
Wj i
Christa Bearry,Ll ista,)
IDAHO POWER COMPANY’S SECOND RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -11