20130926Staff 62-69 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
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
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)) CASE NO. rPC-E-r3-16
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR INVESTMENT IN ) SIXTH PRODUCTION
SELECTIVE CATALYTIC REDUCTION ) REQUEST OF THE
CoNTROLS ON JrM 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 as soon as possible but no later than
FRTDAY, OCTOBER 4, 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
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF SEPTEMBER26,2OI3
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. 62: Please provide a copy of the Air Quality Permit issued by the
Wyoming Department of Environmental Quality (WDEQ) associated with the Project that was
viewed onsite under the Company's response to Production Request No. 21.
REQUEST NO. 63: Please describe in general and in detail the measures or procedures
Idaho Power has in place to ensure that PacifiCorp only incurs prudently incurred costs in the
project design and implementation of Jim Bridger Nos. 3 and 4 catalytic controls.
REQUEST NO. 64: In the Company's response to Staff Production Request No. 32, the
Company said, o'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." Please provide all documentation, including invoices, purchase
orders, etc. that reflects the total costs.
REQUEST NO. 65: Please provide a description, assumptions, and calculation for the
cost labeled "capital surchargeo' on the spreadsheet the Company provided in response to Staff
Production Request No. 32.
REQUEST NO. 66: Please provide copies of PacifiCorp's contracts and/or purchase
orders (PO) that represent the costs reflected in the column labeled "total costs actuals and
estimates through 1213112013" shown in the spreadsheet provided in response to Staff
Production Request No. 32. Please provide them sorted by the work breakdown structure (WBS)
element shown in the first column of the spreadsheet.
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF SEPTEMBER26,2OI3
REQUEST NO. 67: Please provide copies of any studies that were produced as a result
of the POs and/or contracts in Staff Production Request No. 66.
REQUEST NO. 68: Please provide the actual amounts expended as of 5/3112013 and
the authorized amounts for each contract and PO referenced in Staff Production Request No. 66.
Also provide the status of the PO's and contracts stating whether the contracts and PO's are open
or closed for additional spending. If the PO or contract is open for additional spending, please
show how much of the remaining amount is reflected in each of the commitment estimate cost
categories (i.e. Development Phase, EPC Contract, Boiler and Pre-heater Reinforcement Work,
etc.).
REQUEST NO. 69: Please describe the method used to ensure that each PO and
contract described in Staff Production Request No. 66 was procured prudently and at a
reasonable cost.
Dated at Boise, Idaho, tni, /Pday of September 2013.
Technical Staff: Mike Louisl62 - 69
i:umisc:prodreq/ipce 13. I 6ksml prod req 6
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF
Deputy Attorney General
SEPTEMBEP.26,2OI3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF SEPTEMBER 2013,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-I3.I6, BY
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
JENNIFER REINHARDT-TES S MER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
j reinhardt@j dahopower. com
dockets@idahopower. com
C B earry(@ idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS
5I5 N 27TH ST
BOISE ID 836I6
E-MAIL: [e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
E-MAIL: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: kmiller@sn4eriveralliance.o{e
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: ioe(Emcdevitt-miller.com
CERTIFICATE OF SERVICE