20131008IPC to Staff 64,66,67,68.pdf

LISA D. NORDSTROM
Lead Gounsel
I [e-mail]
October 8,2013
l.t rL:. li r!
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W est Washi ngton Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-16
Certificate for Public Convenience and NecessityforJim Bridger Units 3 and
4 - ldaho Power Company's Response to Production Request Nos. 64, 66,
67, and 68 of the Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to Production Request Nos. 64, 66, 67, and 68 of the
Commission Staff ("Staff') to ldaho Power Company.
Also, enclosed are four (4) copies of a confidential disk containing information
responsive to Staffs Production Request Nos. 64 and 67. Please handle the confidential
information in accordance with the Protective Agreement executed in this matter.
Sincerely,
,<r- L.(^on"-*-
Lisa D. NordstroYn
LDN:evp
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
JENNIFER M. REINHARDT-TESSMER (!SB No. 7432)
ldaho Power Company
1221West ldaho Street (83702\
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ idahopower. co m
irei n ha rdt@ id ahopower. co m
Attorneys for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSIW FOR THE INVESTMENT
IN SELECTIVE CATALYTIC REDUCTION
CONTROLS ON JIM BRIDGER UNITS 3
AND 4.
'.'a :i nrT .
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)) CASE NO. rPC-E-13-16
)) TDAHO POWER COMPANY',S
) RESPONSE TO PRODUCTTON
) REOUEST NOS.64, 66,67, AND
) 68 OF THE COMMTSSTON
) STAFF TO IDAHO POWER
) CoMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compory"), and in
response to Production Request Nos. 64, 66, 67, and 68 of the Commission Staff
("Staff') to ldaho Power Company dated September 26, 2013, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
64, 66, 67, AND 68 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 64: ln the Company's response to Staff Production Request No.
32, the Company said, "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 tota! costs.
RESPONSE TO REQUEST NO. 64: On a monthly basis, ldaho Power Company
receives updated cost data from PacifiCorp that contains the detail of charges related to
the Bridger plant. Please note the confidential Excel file (Attachment 1) represents the
unallocated tota! project costs. The confidential file has been filtered for charges
pertaining to the Selective Catalytic Reduction ('SCR") projects (approximately 4,800
lines), and is being provided as support for the actual charges for the SCR projects for
the 201 1, 2012, January 1, 2013, through May 31 , 2013, and June 1 , 2013, through
August 31, 2013, time period. In addition, the Company has provided a confidential
summary of charges (Attachment 12 and Attachment 13), prepared by PacifiCorp, for
the SCR projects by Work Breakdown Structure (WBS) element, and the confidential
purchase orders pertaining to purchases from outside vendors (Attachment 2 thru
Attachment 11). This summary reflects the most current project costs through August
31, 2013. ldaho Power has performed a reconciliation between the summarized cost
data through August 31, 2013, and the PacifiCorp summary of project costs that begins
on line 251 of the attached file. The PacifiCorp summary presents the actual project
costs through August 31,2013, along with the remaining amounts expected to be spent
during the remainder of 2013.
The attachments provided in response to this Request are confidential and will
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
64, 66, 67, AND 68 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
be provided on the confidential CD to those parties that have signed the Protective
Agreement in this matter.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
64, 66, 67, AND 68 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
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.
RESPONSE TO REQUEST NO. 66: Please see the confidential attachments
provided in the Company's response to Staff's Production Request No. 64 for all
documents pertaining to this request.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
64, 66, 67, AND 68 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
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.
RESPONSE TO REQUEST NO. 67: The following confidential studies provided
by PacifiCorp are provided on the confidential CD:
. Design Basis Studies-Jim Bridger Units 3 and 4 SCR System, Sargent
and Lundy (Attachment 1);
. Results of Baseline Testing, Eagle Mountain Scientific lnc. (Attachment 2);
o Permit Application AP-l3260-Evaluation of Potential PMz.s Emission
PMz.s Best Available Control Technology Analysis-Jim Bridger
Generating Station, CH2MHill (Attachment 3).
The confidential CD will be provided 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, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
64, 66, 67, AND 68 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO. 68: Please provide the actual amounts expended as of
513112013 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. lf 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.).
RESPONSE TO REQUEST NO. 68: Please see the confidential attachments
provided in response to Staffs Production Request No. 64 for all documents pertaining
to this request.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
DATED at Boise, ldaho, this 8th day of October 2013.
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
64, 66, 67, AND 68 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day of October 2013 ! served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION
REQUEST NOS. 64, 66, 67, AND 68 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
Kristine A. Sasser
Deputy Attorney General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Industrial Gustomers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 837OT
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Idaho Conselvation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, Idaho 83702
Snake River Alliance
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564
Boise, ldaho 83701
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q reg@ richa rd sonad ams. co m
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IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
64, 66, 67, AND 68 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
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IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
64, 66, 67, AND 68 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8