20200928Staff 1-15 to IPC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 5470
Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUME 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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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
CASE NO.IPC.E-20.32
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond Jr., Deputy Attorney General, request that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, or by MONDAY,
ocToBER 19,2020.
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
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3r.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER 28,2020
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide all workpapers and Excel digiral files, with formulas
intact, used to support Attachments to the Application.
REQUEST NO.2: Please provide all workpapers and Excel digital files, with formulas
intact, used to support Exhibits supporting the Direct Testimonies of Larkin and Adelman.
REQUEST NO. 3: For project "P24688 - Boardman - Upgrade Fire Protection " identified
in Exhibit No. 4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "PGF" or Idaho power Company.,IpC',.
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
iii. Organizatibnalchart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost overruns
f. PGE indirect and/or direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER28,2O2O2
NOTE: Where requested information has not been provided, please explain why it was not
provided and how the Company assured the construction of the project at a least cost.
RBQUEST NO. 4: For project " P24806 - BN: Expand Mint. & Weld Shops" identified in
Exhibit No. 4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "PGE,,or Idaho power Company.,IpC,,.
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost overruns
f. PGE indirect and/or direct charges made to the project.
g. IPC indirect and./or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQUEST NO.5: For project " P26266 - BN-Install New Fire Detection Sys" identified in
Exhibit No. 4 of Adelman, DI Testimony, please provide the following:
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 SEPTEMBER28,2O2O
a. Any other project numbers associated with this project either by the operator
Portland General Electric "ro"" or Idaho power company "Ipc".
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
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
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost overruns
f. PGE indirect and/or direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQUEST NO. 6: For project " P26938 - Boardman - Upgrade Ash Handling Sys"
identified in Exhibit No. 4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "PGE" or Idaho power company "Ipc".
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 SEPTEMBER28,2O2O
ii. Scope document
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost ovemrns
f. PGE indirect and./or direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQIIEST NO. 7: For project " P35469 - BN - Replace Coal Dumper Conduit" identified
in Exhibit No. 4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "PGE" or Idaho power Company,.IpC,,.
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER 28,20205
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost overruns
f. PGE indirect andlor direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQUEST NO. 8: For blanket project " PCN094 - Boardman-Purchase Minor Tools &
Equus" identified in Exhibit No.4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "pGE" or Idaho power company "Ipc".
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project correspondence discussing:
i. Change in requirements
ii. Project cost ovemrns
e. PGE indirect and/or direct charges made to the project.
f. IPC indirect and/or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQUEST NO. 9: For blanket project " P24067 - Boardman - Install Platforms" identified
in Exhibit No. 4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "pGE" or Idaho power Company "Ipc".
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER28,2O2O6
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost ovemrns
f. PGE indirect and./or direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQUEST NO. 10: For blanket project " P35591 - As-Built Drawings - Generation"
identified in Exhibit No. 4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "pGE" or Idaho power Company "Ipc,'.
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
iii. Organizational chart
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER 28,20207
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost ovemrns
f. PGE indirect and"/or direct charges made to the project
g. IPC indirect and/or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQUEST NO. 11: For project "BART-Bdmn Air Quality Controls" identified in Exhibit
No.4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "PGE" or Idaho power Company "Ipc".
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER 28,20208
ii. Project delay
iii. Project cost ovemrns
f. PGE indirect and/or direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQUEST NO. 12: For project " P35182 - BN - Replace VSDs for ID Fans" identified in
Exhibit No. 4 of Adelman, DI Testimony please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "PGE" or Idaho Power Company "IpC".
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost ovemrns
f. PGE indirect and./or direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER 28,20209
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
REQUEST NO. 13: For project " BN - Misc. Pumps. Valves, Motors" identified in Exhibit
No. 4 of Adelman, DI Testimony, please provide the following:
a. Any other project numbers associated with this project either by the operator
Portland General Electric "PGF." or Idaho Power Company,,IpC,'.
b. Analysis used to support the capital investment.
c. Requests developed for bidder proposals.
d. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost overruns
f. PGE indirect and/or direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
NOTE: Where requested information has not been provided, please explain why it was not
provided. Please also explain how the Company is assured construction of the project is at
least cost.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY l0 SEPTEMBER 28,2020
REQUEST NO. 14: For the years 2013 through 2020,please provide any SOX
Compliance Reports and internal audit reports with supporting workpapers for the Boardman
facility.
REQUEST NO. 15: Please provide the work order jackets and source documents for the
following 18 projects:
DATED at Boise, Idaho, this Jfu"f septembe r zo2o.
Attorney General
i:umisc:prodreq/ipce20.32jhrk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Proiect Total
27324968 BOARDMAN 26445 BOILER CLEANING SYSTEM UPGRADE $ 37.45s
27301397 BOARDMAN 25452 IIPGRADE SWA BUILDING HVAC CHILLERS $26.07s
27413973 BOARDMAN I-4177 UPGRADE STACK ELEVATOR CONTROLS $20.272
27452711 BOARDMAN 1-1084 7-580 PURCHASE RETIRE VEHICLES 16 $ 17,784
27343976 BOARDMAN 2O1O GENERIC RETIREMENTS $ 15,295
27369026 BOARDMAN I-2099 BN - INSTALL CARTY RESERVOIR FLOW METER $ 11,116
27369028 BOARDMAN I-2114 UPGRADE LUBE OIL PURIFIER CONTROL $ 10,284
27372782 BOARDMAN I-Z70IINSTALL TURB CRANE SAFETY IMPROVEMENTS $ 8,228
27432627 BOARDMAN I-4979 INSTALL POWER/BLOC LOTO DEVICES $ 5,s39
27383259 BOARDMAN I.2OI9 S. SETTLING POND EROSION PREVENTION $ 4.290
27405253 BOARDMAN 1-3992 ENHANCE PHYSICAL SECURITY $ 2.971
27531070 BOARDMAN I-9223 INSTALL TRONA INJECTION SHIELDS $2.248
27405s60 BOARDMAN I-4044 BRIDGE CRANE ACCESS LADDER $ r.142
27361904 BOARDMAN 1-1506 INSTALL PLATFORMS 12 $ 209
27390675 BOARDMAN 26256 INSTALL WATER RECOVERY $ 103
27324967 BOARDMAN 26444 COMBUSTION CONTROLS LNB OFA $76
27405227 BOARDMAN CONSTRUCTION OVERHEAD WORK ORDER 2014 $ (1,s88)
27344472 BOARDMAN UNDISTRIBUTED WORK ORDER $ (12s,028)
ll SEPTEMBER 28,2020
CERTTFICATE OF SERVICE
I I{EREBY CERTIFY THAT I HAVE THIS 28th DAY oF SEPTEMBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-32,
BY E-MAILING A COPY TI{EREOF, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
dockets @ idahopower.com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE TD 83702
E-MAIL: [e-mail]
SECRET Y
CERTIFICATE OF SERVICE