20191120Staff 18-22 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 r 4
IDAHO BARNO. 10446
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO DECREASE ITS RATES
FOR ELECTRIC SERVICE FOR COSTS
ASSOCIATED WITH THE BOARDMAN
POWER PLANT
l'::lIlVED
. i t,..r 2fl Pll L: 55
I cll'ri'iisrol
Street Address for Express Mail:
1I331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attomey for the Commission Staf'f
BEFORE THE IDAHO PUBLTC UTILITIES COMMISSION
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CASE NO. IPC-E-I9-32
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Stalf of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attomey General, request that Idaho Power Company (Company) provide
the following documents and infbrmation as soon as possible, or by WEDNESDAY'
NOVEMBER 21,2019.1
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 of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
SECOND PRODUCTION REQUEST
TO IDAHO POWER NOVEMBER 20, 20I9
I Staffis requesting an expedited response. These requests formalize Audit Requests previously made by staffonsite.
Ifresponding by this date will be problematic, please call Staffs attomey at [phone].
I
different the witness who can sponsor the answcr at hearing if need be. Rel'erence IDAPA
3 1 .01 .01 .228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic tiles on CD with fbrmulas activated.
REQUEST NO. 18: In reference to Work Order 27300604 "Boardman 24806 Expand
Shop & Warehouse," please reconcile the original estimate of $107,000 (Idaho Power share) with
the final amount of $210,448.32, which includes Idaho Power's AFUDC. Please include with your
response all original detailed source documents showing the individual costs, such as any Boardman
labor, contractor expenses, PGE overhead charged to the project, and any other line item charges.
Please also include an explanation ofwhy the total project costs escalated from $1,070,000 to over
$2.1 million. Please provide any written documentation such as letters, invoices, billing documents,
emails and all other documentation necessary tojustify the total cost for the project, including
change orders, and what steps Idaho Power undertook to ensure that this project was necessary and
that the costs were prudently incurred. In addition, please provide a copy of the information
provided to Staff onsite from the Work Order packet for this project. Furthermore, please provide
copies ofthe information provided onsite in response to Production Request No. 5.
REQUEST NO. 19: In reference to Work Order 27300599 "Boardman 24796 lns New Fire
Detection System," please reconcile the original estimate ol $ 107,120 (Idaho Power share) with the
final amount of $ 178,339.17, which includes Idaho Power's AFUDC. Please include with your
response all original detailed source documents showing the individual costs, such as any Boardman
labor, contractor expenses, PGE overheads charged to the project, and any other line item charges.
Please also include an explanation ofwhy thc total pro.iect costs escalated from about $l million to
over $l .6 million. Please provide any written documentation such as letters, invoices, billing
documents, emails and all other documentation necessary to justify the total cost for the proiect,
including Change Orders, and what steps ldaho Powcr undertook to ensure that this project was
necessary and that the costs were prudently incurred. In addition, please provide a copy ol' the
information provided to Staffonsite from the Work Order packet for this project.
SECOND PRODUCTION REQUEST
TO IDAHO POWER )NOVEMBER 20,2OI9
REQUEST NO.20: In reference to Work Order 27385087 "BDMN l-2702 Install Sewage
Lagoon Liner," please reconcile the original estimate of$46,800 (Idaho Power share) with the final
amount of$78,534. Please include with your response all original detailed source documents
showing the individual costs, such as any Boardman labor, contractor expenses, PGE overheads
charged to the project, and any other line item charges. Please also include an explanation of why
the total project costs escalated from about $468,000 to $785,342. Please provide any written
documentation such as letters, invoices, billing documents, emails and all other documentation
necessary to justify the total cost for the project, including Change Orders, and what steps Idaho
Power undertook to ensure that this project was necessary and that the costs were prudently
incurred. In addition, please provide a copy of the infbrmation provided to Staff onsite from the
Work Order packet for this project.
REQUEST NO.2l: In reference to Work Order 27385087 "BDMN 1-2702 Install Sewage
Lagoon Liner," please explain w'hy Idaho Power customers should pay for any work done for this
project since PGE intends to continue utilizing the lagoon for the "future Carty generation facilities"
as shown in the iustification section, the Impacts and issues section, and the Risks, Dependencies &
Constraints section ofthe Project Justification Form.
REQUEST NO.22: In reference to Work Order 27385087 "BDMN l-2702 Install Sewage
Lagoon Liner," the Thermal Plant Work Order Closings' document shows that Idaho Power paid
I 0% of the costs to PGE for this project. According to the response to Production Request No. 7, a
500% ownership interest in the Wastewater Ponds was transl'erred to PGE. Please describe and
provide documentation justirying why Idaho Power is still responsible for l0% ofthe costs for this
project, instead of 5% as with all the other shared lacilities where 50% ofldaho Power's ownership
interest was transl'erred to PGE in 2014.
SECOND PRODUCTION REQUEST
TO IDAHO POWER .,)NOVEMBER 20. 20I9
DATED at Boise, Idaho, this 2d^- aay of tlovember 2019.
.>-LJ(
Edward Je(c'\-
Deputy Atto-tnby General
iiumisc:prodreq/ipce I 9.32ejrkklsrf prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 NOVEMBER 20,2OI9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE TIIIS 20th DAY OF NOVEMBER 2019.
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-8.I9.32,
BY MAILING A COPY THEREOF. POSTAGE PREPAID. TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: lnordstrom(Aidahapsyq.cau
docket idaho wer.c l
MATT I-ARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: nrlarkin daho
SE I
CERTIFICATE OF SERVICE