20130910Staff 49-61 to IPC.pdf

KRISTINE A. SASSER ;-.;1,- , ,
DEPUTY ATTORNEY GENERAL
rDAHO PUBLTC UTTLTTTES COMMTSSTON ?il:i SIp I 3 ,:,ii ll: ?gPOBOX 83720 _^^ AA_t ,BOISE,IDAHO 83720-0074 r,.,.,,i,,,,,r -.i l(208)334-0357 i; rr
BAR NO. 6618
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A ) CASE NO. rPC-E-13-16
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY F'OR INVESTMENT IN ) FIFTH PRODUCTION
SELECTIVE CATALYTIC REDUCTION ) REQUEST OF THE
CONTROLS ON JIM BRTDGER UNrTS 3 AND 4. ) COMMTSSTON STAFF TO
) rDAHO 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 24, 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
record holder and, if different, the witness who can sponsor the answer at hearing. Reference
IDAPA 31.01.01.228.
FIFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF SEPTEMBER 10,2013
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. 49: Please provide a justification for the $333,333 difference in the
contingency budget for Jim Bridger Units 3 and 4 (see Staff Production Request No. l).
REQUEST NO. 50: Please provide copies of all Aurora input and output files, analysis,
and worksheets (with all formula intact) used to develop the total portfolio costs for Jim Bridger
Unit 3 and Jim Bridger Unit 4 shown in Figure 4 (page 16) of the Coal Unit Environmental
Investment Analysis.
REQUEST NO. 51: Please provide the resource portfolio used as a baseline to conduct
the Total Portfolio Cost analysis for each of the three alternatives (install SCR, retire and replace
with CCCT, and natural gas conversion) contained in the Coal Unit Environmental Investment
Analysis. Please provide the name, type, and net dependable capacity in MW for each resource
in the portfolio.
REQUEST NO. 52: Please provide the resource portfolio used to determine the
Projected Generation Forecast contained in Table 4-26 of the SAIC Coal Environmental
Compliance Upgrade Investment Evaluation. Please provide the name, type, and net dependable
capacity in MW for each resource in the portfolio.
REQUEST NO. 53: Power plant and coal mine reclamation/decommissioning costs will
eventually be incurred for all three alternatives (install SCR, retire and replace with CCCT, and
natural gas conversion). Were these costs amortized and included in the Net Present Value
(NPV) Total Portfolio Cost analysis for each of the three altematives for Jim Bridger Units 3 and
4 as reflected in Figure 4 of the Coal Unit Environmental Investment Analysis? If not, please
provide the incremental NPV cost impact for each alternative and natural gas/carbon future.
REQUEST NO. 54: Please describe what the Company believes are the mercury, acid
gas and other hazardous air emissions limits applicable for each Bridger unit pursuant to the final
FIFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF SEPTEMBER 10,2013
Mercury and Air Toxics Standards (MATS) and a description of the controls and investments
needed to meet compliance for each limit (l.lote: this request can be combined with Staffs
Request No. 39 but seeks more detailed clarification for the specific types of controls and costs
for each).
REQUEST NO. 55: The EPA has proposed amendments to the effluent limitations
guidelines and standards for steam electric power generation plants on June 7,2013 (40 CFR
Part 423). What additional investments would be needed to comply with the new standards?
Has a proxy cost of these investments been factored into the Net Present Value Total Portfolio
Cost analysis for each of the three alternatives (install SCR, retire and replace with CCCT, and
natural gas conversion) for Jim Bridger Units 3 and 4 as reflected in Figure 4 of the Coal Unit
Environmental Investment Analysis? If not, please provide a basis for the incremental cost and
the incremental NPV cost impact for each alternative and natural gas/carbon future.
REQUEST NO. 56: Please describe Idaho Power's role and specific responsibilities in
the following: (l) developing the Engineering, Procurement, and Construction (EPC) contractor
Request for Proposal (RFP); (2) evaluating the proposals; (3) selecting the contractor; and (a)
developing the final contract.
REQUEST NO. 57: For the EPC contract, what was the basis for the $2 million
additional cost using a Limited Notice to Proceed type of contract? Please provide a breakdown
of the specific costs and a description of each.
REQUEST NO. 58: The boiler and air pre-heater reinforcement work, the economizer
upgrades, the low-load economizer exit gas temperature control systems, and the flue gas
reinforcement are listed to be contracted at a later date separate from the EPC contract in the
EPC contractor's proposal as if the need was still under evaluation. How certain is the Company
that each of these additional parts of the project will be needed for each Jim Bridger unit? Please
explain.
FIFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF SEPTEMBER 10,2013
REQUEST NO. 59: How would the Company run Bridger Units 3 and 4 if converted to
be fueled by natural gas (e.g., baseload, intermediate, peaking)? What capacity factor is
anticipated for each unit?
REQUEST NO. 60: Please explain the difference in minimum Net Present Value Total
Cost outcomes for Jim Bridger Units 3 and 4 (Table 4.1) between the final SAIC report and the
draft report dated 811312012. Specifically, why did the lowest cost alternative for (1) low
gas/high carbon change from retire and replace to natural gas conversion; and (2) for base
gas/high carbon change from retire and replace to the upgrade alternative.
REQUEST NO. 61: Please explain the difference in minimum Total Portfolio Cost Net
Present Value outcomes for Jim Bridger Units 3 and 4 between the 1012612012 final draft of the
Coal Unit Environmental Investment Analysis (Figure 6) and the final report (Figure 4).
Specifically, why did the lowest cost altemative for (1) base gas/high carbon change from natural
gas conversion to the upgrade alternative; (2) high gas/high carbon change from natural gas
conversion to the upgrade altemative; and (3) low gas/high carbon change from natural gas
conversion to retire and replace.
Dated at Boise, Idaho, this day of September 2013.
Technical Staff: Mike Louisl49 - 6l
i:umisc:prodreq/ipcel 3. I 6ksml prod req 5
FIFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF
Deputy Attorney General
SEPTEMBER IO,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1OTH DAY OF SEPTEMBER 2013,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-I3-16, 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
BOrSE rD 83707-0070
E-MAIL: [e-mail]
j reinhardt@idahopower. com
dockets@idahopower. com
C B earry@ idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS
515 N 27TH ST
BOISE ID 83616
E-MAIL: [e-mail]
gre [e-mail]
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
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE ID 83702
E-MAIL: j [e-mail]
CERTIFICATE OF SERVICE