20191127IPC to Staff 18-22.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
RECEIVED
i0l9HOV 27 Pl1?:09
November 27,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-19-32
Rate Decrease for Costs Associated with the Boardman Power Plant
ldaho Power Company's Response to the Second Production Request ofthe
Commission Staff
Dear Ms. Hanian:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to the Second Production Request of the Commission Staff.
Also enclosed is a confidential disk containing information provided in response to
Staff s production requests.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
Lisa D. Nordstrom
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Enclosures
RECEIVED
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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
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CASE NO. |PC-E-19-32
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
Company dated November 20,2019, herewith submits the following information:
IDAHO POWER COIVIPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF . 1
LISA D. NORDSTROM (lSB No. s733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
REQUEST NO. 18: ln reference to Work Order 27300604 "Boardman 24806
Expand Shop & Warehouse," please reconcile the original estimate of $107,000 (ldaho
Power share) with the final amount of $210,448.32, which includes ldaho 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 of why 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 to justify the total cost for the
project, including change orders, and what steps ldaho Power undertook to ensure that
this project was necessary and that the costs were prudently incurred. ln addition,
please provide a copy of the information provided to Staff onsite from the Work Order
packet for this project. Furthermore, please provide copies of the information provided
onsite in response to Production Request No. 5.
RESPONSE TO REQUEST NO. 18: Please see Confidential Attachments 1-7
provided on the confidential CD which contains files supporting the expansion of the
Boardman shop and warehouse, including a reconciilation of the original proiect cost
with the final amount, the work order packet documentation, the Purchase Order
Executive Summary, the Final Bid Review, the Shop Expansion Purchase Order, and
the Change Log. 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 Randy Henderson, Principal Joint
Projects Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COI\ilMlSSlON STAFF - 2
REQUEST NO. 19: ln reference to Work Order 27300599 "Boardman 24796 lns
New Fire Detection System," please reconcile the original estimate of $107,120 (ldaho
Power share) with the final amount of $178,339.17, which includes ldaho 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 of why the total project costs escalated from about $1 million to over
$1.6 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
project, including Change Orders, and what steps ldaho Power undertook to ensure that
this project was necessary and that the costs were prudently incurred. ln addition,
please provide a copy of the information provided to Staff onsite from the Work Order
packet for this project.
RESPONSE TO REQUEST NO. 19: Please see Confidential Attachments 1-13
provided on the confidential CD which contains files supporting the installation of the
new fire detection system, including the technical requirements and specification
documents, the internal bid scoring sheet, vendor quotations, Purchase Requisition
Request, Phase ll Schedule of Values, the work order packet documentation, and a
reconciliation of the original project cost with the final amount. 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 Randy Henderson, Principal Joint
Projects Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 20: ln reference to Work Order 27385087 "BDMN 1-2702 lnstall
Sewage Lagoon Liner," please reconcile the original estimate of $46,800 (ldaho 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 ldaho
Power undertook to ensure that this project was necessary and that the costs were
prudently incurred. ln addition, please provide a copy of the information provided to
Staff onsite from the Work Order packet for this project.
RESPONSE TO REQUEST NO. 20: Please see Confidential Attachments 1-2
provided on the confidential CD which contains work order packet documentation and a
reconciliation of the original project cost with the final amount. The confidential CD will
be provided to those parties that have executed the Protective Agreement in this matter.
ldaho Power is awaiting additional source documents from Portland General Electric
('PGE) and the Boardman plant and will provide the information as soon as it becomes
available.
The response to this Request is sponsored by Randy Henderson, Principal Joint
Projects Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 4
REQUEST NO. 21: ln reference to Work Order 27385087 "BDMN 1-2702 lnstall
Sewage Lagoon Liner," please explain why ldaho 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 justification section, the lmpacts and
issues section, and the Risks, Dependencies & Constraints section of the Project
Justification Form.
RESPONSE TO REQUEST NO. 21: The Water Pollution Control Facilities
('WPCF) permit issued by the Oregon Department of Environmental Quality ('DEO')
for the Boardman facility in 2012 dictated that the onsite clay-lined sewage lagoons be
evaluated and reconditioned. ln 2014, it was determined that the two clay-lined sewage
lagoons northeast of the power block building needed relining with a new synthetic liner
system per the WPCF and DEQ regulations. Upon further evaluation, flow estimates
from both the Boardman and Carty generation facilities showed that one pond, in its
current size, would be adequate for normal service conditions. As a result, the
remaining clay-lined pond was taken out of service. The installation of the sewage
lagoon liner was required as it is now the only sewage lagoon available for service to
Boardman. As described in more detail in the Company's Response to Request No. 22,
under the Asset Purchase Agreement ("APA") with PGE, the Company conveyed 5
percent of its ownership interest in the Wastewater Ponds, including the sewage lagoon,
as they are assets identified as those that would be shared between the Boardman and
Carty generating facilities.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company,
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMIUISSION STAFF .5
REQUEST NO. 22: ln reference to Work Order 27385087 'BDMN 1-2702 lnstall
Sewage Lagoon Liner," the Thermal Plant Work Order Closings' document shows that
ldaho Power paid 10% of the costs to PGE for this project. According to the response
to Production Request No. 7, a 50% ownership interest in the Wastewater Ponds was
transferred to PGE. Please describe and provide documentation justifying why ldaho
Power is still responsible for 10o/o of the costs for this project, instead of 5% as with all
the other shared facilities where 50% of ldaho Power's ownership interest was
transferred to PGE in 2014,
RESPONSE TO REQUEST NO. 22: ldaho Power has confirmed that the
Company was charged by PGE for 10 percent of the costs associated with the
installation of a sewage lagoon liner, an investment associated with the Wastewater
Ponds. The Wastewater Ponds are one of a few investments that were identified as
Shared Facilities under the APA between ldaho Power and PGE. Therefore, ldaho
Power conveyed 5 percent of the Company's ownership in the Wastewater Ponds to
PGE in 2014. Under Section 6 of the APA, from and after the effective date, capital
additions to the Shared Facilities should be allocated to ldaho Power at 5 percent. The
Company has notified PGE of the error. ln addition, ldaho Power reviewed the work
order detail descriptions and has not identified any additional investments made to the
Shared Facilities assets since execution of the APA.
The response to this Request is sponsored by Randy Henderson, Principal Joint
Projects Coordinator, ldaho Power Company.
DATED at Boise, ldaho, this 27th day of November 2019.
IS D. NORD T M
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF .6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 27th day of November 2019 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COIUMISSION STAFF .7
lo
Kim rly T , Executive Assistant
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