20150618Staff 1-7 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AN ORDER
AUTHORIZING THE APPROVAL OF A LONG
TERM PROGRAM CONTRACT WITH
SIEMENS ENERGY,INC., AND DEFERRAL OF
ASSOCIATED COSTS.
7$1i
BEFORE THE IDAHO PUBLIC UTILTTIES COMMISSION
I f; l\l'i tl' 33
CASE NO. IPC.E.IS-I7
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Company) provide the following documents and information as soon as possible, by
THURSDAY, JULY 9,2015.
This Production Request is to be considered as continuing, and the 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identiff the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JUNE 18,20I5
REQUEST NO. 1: Please provide a copy of Exhibit No. I in an electronic Excel format
with all formulas intact.
REQUEST NO.2: Page 6,line22-25 through pageT,line 1 of Trevor Mahlum's direct
testimony states "However, Idaho Power did contract with a professional knowledgeable in long-
term program contracts who contacted multiple third-party providers of gas plant maintenance as
part of a formal request for information process."
a. Please identify the professional.
b. Please identify the third-party providers.
c. Please provide a copy (or access to a copy) ofeach proposal received.
d. Please explain the criteria used to evaluate the proposals.
e. Please provide a copy of the proposal evaluation results.
REQUEST NO. 3: Please provide a schedule showing the expected timing and amounts
for all milestone payments.
REQUEST NO. 4: Please explain whether response time for unscheduled maintenance
or repairs will be adversely affected if spare parts are no longer on-site or in the Company's
inventory.
REQUEST NO. 5: In multiple areas of testimony and the Application, the Company
discusses buying parts under the current self-manage approach, rather than using parts already in
the Company's inventory.
a. Please explain generally which parts are currently in the Company's inventory and
which must be ordered as needed.
b. Which parts are included in those whose ownership will be transferred from the
Company to Siemens?
c. Please provide a schedule showing all inventory to be transferred to Siemens with as
much detail as possible for the net book value and taxes for each component.
d. Please distinguish between "Initial Spare Parts" and "Program Parts."
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 18,2015
REQUEST NO. 6: Please list the OEM-recommended scheduled maintenance intervals
for each plant.
REQUEST NO. 7: The LTP contract appears to only cover the Langley Gulch CCCT,
the Bennett Mountain SCCT, and the Danskin #l SCCT, but not the Danskin#2 or Danskin #3
SCCT.
a. Please confirm whether this is correct. If it is correct, why have Danskin #2 and
Danskin #3 units been omitted?
b. Will maintenance of Danskin #2 arrd Danskin #3 units continue to be self managed by
the Company?
c. Does the Company have spare parts in inventory specifically for the Danskin #2 and
Danskin #3 units? Will the Company continue to own these parts if the LTP contract
is approved?
Karl T. Klein
Deputy Attorney General
DATED at Boise, Idaho, this ' fr day of June 2015.
lU //c
Technical Staff: Rick Sterling
i:umisc:prodreq/ipcel5.9kkrps prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY oF JUNE 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAF',F TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E.Is-I7, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
dockets@ idahopower. com
TIMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
CERTIFICATE OF SERVICE