20191107Staff 1-17 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC I.JTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. I0446
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION F'OR
AUTHORITY TO DECREASE ITS RATES
FOR ELECTRIC SERVICE FOR COSTS
ASSOCIATED WITH THE, BOARDMAN
POWER PLANT
FIRST PRODUCTION REQUEST
TO IDATIO POWER
RiCEIVED
i;;l licY -? Pt't t: 59
CASE, NO. IPC.E-I9-32
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
,:i'
(',01 *\l8t,o*
Slreet Address fbr Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 20I.A
BOISE, ID 837I4
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attomey General, requcst that Idaho Power Company (Company) provide
the following documents and information as soon as possible, or by FRIDAY,
NOVEMBER 15,2019.t
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source ol'information used in calculations. The Company is reminded that responses pursuant
to Commission Rules olProcedure must include the name and phone number of the person
preparing the document. and the name, location and phone number ofthe record holder and if
I Staffis requesting an expedited rcsponse. Ifresponding by this date will be problematic, please call Staffs anomey at
[phone].
NOVEMBER 7.2019
different the witness who can sponsor the answer at hearing ifneed be. Reference IDAPA
3 I .01.01.228.
In addition to the writtcn copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST N0. l: Please provide all workpapers and Excel digital files, with formulas
intact, used to support Attachment 1 ofthe Application.
REQUEST NO.2: Please provide all workpapers and Excel digital files, with formulas
intact, used to support Exhibit No. I and 2 ofLarkin, DI Testimony.
REQUEST NO.3: Pease provide all documentation since 20[2 bctween the Company and
its partner, Portland General Electric (PGE). showing how the Company actively engaged with PGE
to minimize costs attributed to plant investments in relation to the lbrecasted amounts frled in 2012,
'fhese documents would likely question the necd for an upgrade and/or likewise explore potential
alternatives for minimizing cost, especially given the plant's short remaining lif'e.
REQUEST NO.4: Please provide guidelines and procedures used by the Boardman plant
(ldaho Power Company/Portland General Electric) to develop and complete project capital
investments at the plant.
REQUEST NO. 5: For proj ecr "27300604 BOARDMAN 24806 EXPAND SHOP &
WAREHOUSE" identified in accounting year 2013, please provide the following:
a. Analysis used to support the capital investment.
b. Request developed for bidder proposals.
c. Project construction documentation including:
i. Constructioncontract
ii. Scope document
iii. Organizationalchart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
FIRS'I' PRODUCTION RH,QUESI'
1'O IDAHO POWER 2 NOVEMBER 7,2019
vi. Action items list(s)
vii. Contractor change order requests
NOTE: Where requested information has not been provided, please explain why it was not provided
and further how the Company assured the construction ofthe project at a least cost.
REQUEST NO.6: Forproject27363452 BOARDMAN l-1760 SO2 CONTROLS
MODIFICATION BART identified in accounting year 2014, please provide the following:
d. Analysis used to support the capital investment.
e. Request developed for bidder proposals.
f. Project construction documentation including:
i. Constructioncontract
ii. Scope document
iii. Organizationalchart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
NOTE: Where requested information has not been provided, please explain why it was not provided
and further how the Company assured the construction ofthe project at a least cost.
REQUEST NO.7: Please provide the Company's analysis and explain the reasoning for
the sale ofassets under the APA in year 2014 to Portland General Electric (PGE). Further, please
identify all assets sold under this agreement.
REQUEST NO. 8: Please explain the current requirements for renovation of the ash field.
Please explain any differences in costs or requirements relative to the requirements expected in
2012.
REQUEST NO.9: Please explain the current Boardman plant approach for disposing of
any remaining coal on site at the end of 2020. When thc plant is closed, will any remaining coal on
site be required to be landfilled? Ifso, please explain why and quantity the cost.
FIRS'I' PRODIJCTION RIiQLrlrS'l'
TO IDAHO POWER 3 NOVEMBER 7,20I9
REQUEST NO. 10: In relbrence to the Boardman Balancing Account, please providc an
Excel spreadsheet with work orders and/or project numbers for the Boardman additions that have
closed to plant in service from January l, 201 7 through December 3 I , 201 8 or havc been included
in the balancing account dudng that same time period. Please provide copies ol all work orders and
all supporting documentation for the actual capital investments fbr 20 | 7 and 201 8.
REQUEST NO. l1: Plcase provide the Audit Reporls fiom the external auditor lor the
Boardman Trust for the years 2016 through 2019.
REQUEST NO. 12: In reference to the Boardman Balancing Account, please provide thc
forecast and budget documents preparcd by Portland General Elcctric for the Boardman plant for
the years 201 2 through 2020. ln addition, please provide the calculation and supporting
documentation for the "adder" that Idaho Power includes in the calculation ofthe actual and
forecast lbr the Boardman Balancing account.
REQUEST NO. l3: In reference to the Boardman Balancing Account, plcase provide the
underlying supporting information (actual kWhs sold or other similar documentation used) for the
actual revenue true up collections for 2017 and 201 8.
REQUEST NO. 14: Please provide any intemal audit reports and supporting workpapers
for the Boardman lacility. In addition, please provide any Sarbanes-Oxley results that pertain to the
Boardman facility.
REQUEST NO. 15: Please provide copies olBoardman Capital Investment Source
Documents for the period from June 2012 through December 2018 for onsite review.
REQUEST NO. 16: Please provide proj ect description, costs. and dates for unplanned
investments or those investments that wcren't included in the last "projccted additions" to the
Boardman plant through December 31,2018.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 NOVEMBER 7,20I9
REQUEST NO. l7: Please provide a copy of the report prepared by CH2M Hill in 2015
for the decommissioning, demolition, and final closure plan for Boardman. In addition, Matt
Larkin's testimony on page l6 rel'ers to a request lbr proposal by Portland General Electric "seeking
an owner's engineer to complcte design and permitting work in preparation fbr decommissioning
activities in 2019. . . " Please provide a copy of this updated decommissioning cost study when it
becomes available.
DATED at Boise, Idaho, this 7Y\day ofNovember 2019.
Edu'ard J
Deputy Att General
Technical Sralt Rick Keller (1-9)
Kathy Stockton ( l0- l 5, I 7)
Rachelle Farnsworth ( l6)
i:unisc:prodreq/ipoel9.32ejrkklsrf prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 NOVEMBER 7,2019
(
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OI.- NOVEMBER 2019.
SERVED THE FOREGOING F'IRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC.E.I9-32,
BY MAILING A COPY THEREOF. POSTAGE PREPAID. TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail: lnordstro DO\\'er.coln
docketsr'ri)idahopowcr.corn
S CRET
CERTIFICATE OF SERVICE
MATT LARKIN
IDAHO POWERCOMPANY
PO BOX 70
BOISE rD 83',t07-0070
E-mail : [e-mail]