20170321ICL & Sierra Club 4-1 to 4-7 to IPC.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSIQN , ; I pi,l 2: Lr g
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IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHOzuTY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE NORTH
VALMY PLANT
Travis Ritchie
Sierra Club Law Program
2l0l Webster Street, Suite 1300
Oakland, CA94612
trav is. ritchie@sierrac lub.org
CASE NO. IPC.E.16.24
FOURTH SET OF DATA
REQUESTS OF SIERRA CLUB
AND IDAHO CONSERVATION
LEAGUE TO IDAHO POWER
COMPANY
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Sierra Club and Idaho Conservation League ("ICL") hereby serve their fourth set of data requests
regarding the above-mentioned docket. Siena Club and ICL request that Idaho Power Company
provide responses as expeditiously as possible, but not later than the deadline of 21 days, which
is April 11.2017.
INSTRUCTIONS
Please provide copies of responses to the following contacts
Alexa Zimbalist
Sierra Club Law Program
2l0l Webster Street, Suite 1300
Oakland, CA94612
[e-mail]
Ben Otto
Idaho Conservation League
710 N 6th st.
Boise, ID 83701
botto@idahoconservati on.org
2. Whenever possible, Sierra Club and ICL prefer to receive electronic copies of data
responses either by email or on CD.
3. Responses to any and all of Sierra Club and ICL's data requests should be supplied to
Sierra Club and ICL as soon as they become available to Idaho Power.
4. The requests herein shall be deemed to be continuing in nature and Idaho Power is
requested to supplement its responses as necessary and as additional information
becomes available.
5. In responding to each data request, please consult every document source which is in
your possession, custody, or control, including all documents in the possession of experts
or consultants.
6 For each response, identify the person who prepared the answer to the data request as
well as his or her position with Idaho Power or any Idaho Power affiliate or parent.
Please reproduce the data request being responded to before the response.
If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
If the responses include spreadsheet files, please provide those spreadsheet files in
useable electronic Excel readable format.
10. In responses providing computer files, list the file names with cross-reference to the data
request, and ifnecessary to the understanding ofthe data, provide a record layout ofthe
computer files. Computer files provided with a response must be in or compatible with
the current version, or the immediately prior version, of Microsoft Office.
1 1. For each dollar amount provided in response to a discovery request please state if the
amount is in nominal or constant dollars and what years dollars.
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SC/ICL 4-I
SC/ICL 4.2
SC/ICL 4-3
In The Matter of the Application of Idaho Power Company for Authority to Increase Its
Rates for Electric Service to Recover Costs Associated with the North Valmy Plant
Case No.IPC-E-16-24
Sierra Club and Idaho Conservation League's Fourth Set of Data Requests to
Idaho Power Company
March 21 2017
DATA REQUESTS
Please refer to the Application at paragraph 1 1 (page 6). Please verify that Idaho Power
Company is proposing, in this docket, to include within rates o'all the investments made
between the 201 I test year and July 31,2016."
Refer to Response to Staff Request No. l, file "Attachment 8 - Response to Staff s
Request No. l_Exhibit 6 Workpapers_Fixed Costs (00207922x8CD5C)" tab "Valmy 10
Year budget." ("2015 to 2024 North Valmy Capital Plan")
a. Does this table represent Valmy total costs (irrespective of ownership), or IPC-
share?
b. If this table represents IPC-share, does it represent whole Company, or Idaho
share only?
c. Provide a table of annual actual capital expenditures at Valmy Unit 1, Valmy
Unit2, and at any shared Valmy facilities from 2010 to the present day, broken
down into Budget ID, Unit, and Project Title, as per the referenced worksheet
(to be labeled *2010 to 2017 North Valmy Capital Spend")
d. Refer to IPC Response to Staff DF.22 (Attachments I through 30). Provide a
crosswalk between projects listed in Staff DR 22 and (c) above ("2010 to 2017
North Valmy Capital Spend").
Refer to IPC Response to Staff 22, attachment 28 ("Valmy I Utility MACT")
a. Identify the date upon which this document was provided to IPC from NV
Energy.
b. Identify the individuals (name, department) charged with the review of this
document at IPC.
c. Provide any written internal correspondence at IPC with respect to the review of
this document.
d. Provide any written correspondence with NV Energy with respect to the review
of this document.
e. Identify the date upon which IPC provided approvalto NV Energy to proceed
with with the Valmy I Utility MACT project as scoped in this document.
f. Identifu the date upon which final notice to proceed was provided to the builder
by NV Energy.
g. What was the final cost of this project on a plant-wide basis?
In The Matter of the Application of Idaho Power Company for Authority to Increase Its
Rates for Electric Service to Recover Costs Associated with the North Valmy Plant
Case No. IPC-E-16-24
Sierra Club and Idaho Conservation League's Fourth Set of Data Requests to
Idaho Power Company
March 21,2017
SCIICL 4-4.Refer to IPC Response to Staff 22, attachment 28 ("Valmy I Utility MACT"); refer
specifically to page 5 of 6 ("Cost Benefits Calculations").
a. Verify that this document was provided to IPC by NV Energy.
b. Please provide any workpapers or calculations or spreadsheet versions of this
document that were either generated by IPC or provided by NV Energy.
c, Describe what is represented by the line labeled "Duration of Derate \ hr" in this
specific circumstance. Specifically, page 3 of 6 ("Assumptions") states that
"derated [sic] is based on loss of the unit's ability to operate beyond the
compliance date," so why does the analysis draw on a duration of derate at7200
hours for 2016-2019?
d. Describe what is represented by the line labeled "facility capacity factor."
e. Provide the annual capacity factor of Valmy I from 2003-2013, inclusive.
f. Describe what is represented by the line "probability of occurrence."
g. State if IPC believes that the values of "probability of occurrence" as
documented in this analysis were true and correct at the time it was developed.
h. Describe what is represented by the line "Replacement Power Margin \
$/MWh."
i. Produce any economic analysis of the Valmy I Utility MACT project conducted
by IPC.
SC/ICL 4-5 Refer to the Idaho Power Company's 2013 Integrated Resource Plan ("lRP";
a. Identify the date upon which the final model runs in the 2013 IRP were
conducted.
b. For each of the nine portfolios examined in the 2013 IRP, provide the annual
projected capacity factor for Valmy I through the full analysis period.
c. For each of the nine portfolios examined in the 2013 IRP, provide the annual
production cost (in $/MWh) for Valmy I through the full analysis period.
d. For portfolios 3 through 9 in the 2013 IRP, provide the annual production cost
(in $/\aWh) for the combined-cycle combustion turbine (CCCT) through the
full analysis period.
SC/ICL 4-6. Refer to IPC Response to Staff 22, attachment 4 ("Valmy 2 Cooling Tower, Replace").
a. Identify the date upon which this document was provided to IPC from NV
Energy.
SCIICL 4-7
In The Matter of the Application of Idaho Power Company for Authority to Increase Its
Rates for Electric Service to Recover Costs Associated with the North Valmy Plant
Case No.IPC-E-16-24
Sierra CIub and Idaho Conservation League's Fourth Set of Data Requests to
Idaho Power Company
March 21,2017
b. Identify the individuals (name, department) charged with the review of this
document at IPC.
c. Provide any written internal correspondence at IPC with respect to the review of
this document.
d. Provide any written correspondence with NV Energy with respect to the review
of this document.
e. Identify the date upon which IPC provided approval to NV Energy to proceed
with the Valmy 2 Cooling Tower project as scoped in this document.
t. Identify the date upon which final notice to proceed was provided to the builder
by NV Energy.
Refer to IPC Response to Staff 22, attachment 4 ("Valmy 2 Cooling Tower, Replace");
refer specifically to page 5 of 6 ("Cost Benefits Calculations").
a. Verify that this document was provided to IPC by NV Energy.
b. Please provide any workpapers or calculations or spreadsheet versions of this
document that were either generated by IPC or provided by NV Energy.
c. Confirm or deny:the section entitled "heat rate improvements" assumes a 100%
capacity factor from Valmy for 2016 through 2021.lf not, please state the
capacity factor assumed in the values of "heat rate savings."
d. Produce any economic analysis of the Valmy 2 Cooling Tower Replacement
project conducted by IPC.
CERTIFICATE OF SERVICE
I hereby certify that on this 2l't day of March2017,I delivered true and corect copies of the
fbregoing FOURTH SET OF DATA REQUESTS OF SIERRA CLUB AND IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY to the following persons via
electronic mail.
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702
diane.holt@puc. idaho.gov
Idaho Public Utilities Commission
Camille Christen
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702
camille.christen@puc. idaho.gov
IIPA
Eric L. Olsen
ECHOHA WK & OLSEN, PLLC
[e-mail]
Anthony Yankel(C)
12700 Lake Ave. Unit 2505
Lakewood, OH 44107
[e-mail]
MICRON
Pete Bennett
Micron Technology, Inc.
8000 S. Federal Way
Boise,ID 83707
[e-mail]
Idaho Power
Lisa D. Nordstrom
Matt Larkin
Idaho Power Company
l22l W. Idaho St.
Boise, ID 83702
lnordstrom@idahopower. com
mlarkin@idahopower. com
[e-mail]
DOE
Steven Porter
United States Department of Energy
Office of the General Counsel ( GC-76)
1000 Independence Ave., SW, Room 6D-
033 Washington, D.C. 20585
[e-mail]. gov
MICRON
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
Brian T. Hansen
Holland & Hart, LLP
6380 S. Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 801I I
tnelson@ho I landhart.com
[e-mail]
etcoc ian@hol landhart.com
bhansen@ho I landhart.com
[e-mail]
klhall@ho I landhart. com
kmtrease@hol landhart. com
/s/ Alexa Zimbalist
Alexa Zimbalist
Legal Assistant
Sierra Club Environmental Law Program
2l0l Webster Street, Suite 1300
Oakland, CA94612
[e-mail]