20201026IPC to Staff 2nd Partial Response.pdf

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An IDACOnP Companv
October 26,2O2O
VIA ELECTRONIC UAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-20-32
Rate Decrcase for Costs Associated with the Boardman Power Plant
Dear Ms. Noriyuki:
Enclosed for electronic filing, pursuant to Order No. 34602, please find ldaho Power
Company's Second Partial Response to the First Production Request of the Commission Stafi.
Pursuant to Staffs conversation with Matt Larkin of ldaho Power on Friday, October 16,
2020,ldaho Powerfiled responses to Request Nos. 1-5, 12, and 14-15 on October 19,2020.
Due to the volume of documentation requested by Staff in their requests, the remainder of
responses, Response Nos. 6-11 and 13, are being liled today.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
LISA D, NORDSTROT
lead Counrel
lnordsbomOi&hooowar.com
LDN:slb
Attachment(s)
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 388€936
lnordstrom@idahopower. com
Aftorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO DECREASE ITS RATES
FOR ELECTRIC SERVICE FOR COSTS
ASSOCIATED WITH THE BOARDMAN
POWER PI.ANT.
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cAsE NO. !PC-E-20-32
IDAHO PO\A'ER COMPANY'S
SECOND PARTIAL RESPONSE
TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION
STAFF
COMES NOW, ldaho Power Company ('ldaho Powe/ or "Company"), and in
partial response to the First Production Request of the Commission Staff to ldaho Power
Company dated September 28,2020, herewith submits the following information:
IDAHO POVI/ER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF . 1
REQUEST NO. 6: For proiect'P26938 - Boardman - Upgrade Ash Handling Sys'
identified in Exhibit No. 4 of Adelman, Dl Testimony, please provide the following:
a. Any other project numbers associated with this project either by
the operator Portland General Electric'PGE" or ldaho Power
Company'lPC'.
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 veraus actual)
v. Monthly projec,t status reports
vi. Action items list(s)
vii. Gontractor 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.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE GOMMISSION STAFF - 2
NOTE: Where requested infonnation has not been provided, please explain why
it was not provided. Please also explain how the Company is assured construc'tion of the
project is at least cost.
RESPONSE TO REQUEST NO. 6: The upgrade of the controlsystem of the ash
handling system was required for the reliability of Boardman. The ash handling system
transfers coalash, the residualfrom buming coalthat includes solid materials, away from
boilers for disposal. Regulations are in place for the safe and efficient transfur and the
systems vary for the different ash residuals. The Boardman ash handling system controls
three systems: the fly ash handling system, the bottom ash handling system, and the
economizer ash handling system.
The existing Boardman controlsystem had been running the ash handling system
for over 30 years and was the original plant equipment. The equipment had been
discontinued by the manufacturer and spare parts on the market were limited, Because
this system removes all the ash produced by the boiler and precipitator and stores it
safely, it can be detrimentalto plant operations if a failure occurs. This project upgraded
the inpuUoutput, logic controllers and communication in the ash handling system.
Due to the current global pandemic, and the voluminous nature of confidential and
non-confidentia! information provided in response to other data requests in this case, the
Company is posting the attachment(s) to this request to the secure FTP site to allow
parties to view the requested information for all data requests, in one place, remotely.
Because certain attachments contain confidential information, the FTP site is password
protected and wil! only be provided to those parties who have executed the Protective
Agreement in this matter. Although the entire set is password protected so that the
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 3
responses could be grouped holistically, documents subject to the protective agreement
are marked .CONFIDENTIAL.'! To gain acoess to the secure FTP site, please contact
Courtney Waites via email at [e-mail].
a. The PGE Project Number is 26938 and the Idaho Power work order number
associated with this proiect is 27369029.
b. Historically, PGE has had on retainer a contractor that remains on-site at
Boardman to assist in a variety of smaller projects at the plant, including
janitorial work, outage and maintenance repairs, small capital projects and
decommissioning assistance. This local crew is retained for the lower cost
projects for which the expense of a bidding process would be more than
that of the contractor or for the smaller projects plant staff was unavailable
to perform the work. When a problem is identified, plant personnelevaluate
the urgency and complexity of the work required. lf it is determined the
contractor on retainer can efficiently, quickly, and cost-effectively perform
the work, the plant contacts the contractor for an estimate of the project
cost.
Given the essential nature of the ash handling system and the ability
of the contractor on-retainer to perform the work efficiently, plant personnel
made the decision to use the on-site contractor to perform the electrical
work required for the upgrade. ln addition, PGE personnel assisted with
the re-writing of the sofhrare.
c. Please see the response to (b) above. There were no bidder proposals
associated with the upgrade of the ash handling system due to the ability
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
of the on-site contractor to efficiently, quickly, and cost-effectively perform
the work.
d. Please see the Confidential Attachment for the detailed construction
package associated with the ash handling system upgrade. There were no
other project construction documents for this project.
e. Please see the response to (b) above. There were no project scope, delay
or cost overrun documents associated with the upgrade of the ash handling
system.
f. The bllowing chart summarizes PGE's direct and indirect charges made for the
upgrade of the ash handling system:
lnternal PGE Labor, Capital Loadings, Other
Miscellaneous Charoes $377.M2
Materials $144.541
Outside Services $202,274
100o/o Total $724.258
g. ldaho Power has recorded $72,526 of investments in the upgrade of the
ash handling system to electric plant-in-service which includes the
Company's 10 percent share of PGE's costs, $72,426, plus $100 of
additional charges associated with ldaho Power loadings and AFUDC.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF . 5
REQUEST NO. 7: For project'P35469 - BN - Replace Coal Dumper Conduit"
identified in Exhibit No. 4 of Adelman, Dl Testimony, please provide the fotlowing:
a. Any other project numbers associated with this project either by
the operator Portland General Electric'PGE" or ldaho Power
Company'lPC'.
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.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
NOTE: \Mrere requested information has not been provided, please explain why
it was not provided. Phase also explain how the Company is assured construction of
the project is at least cost.
RESPONSE TO REQUEST NO. 7: The coal dumper conduit replacement
project required the re-wiring of the dumper with new electrical conduits because they
deteriorated. As seen in Exhibit No. 3, ldaho Power's share of the costs associated
with the project was $14,592. The need for repair was discovered at the beginning
of an outage so the level of work initially required was expected to be minimal.
However, once the work began, it was determined the budgeted project cost of
$50,000 was underestimated. Actual costs were approximately $150,000, resulting
in the 200 percent variance seen in Exhibit No. 4.
a. The PGE Project Number is 35469 and the ldaho Power work order
number associated with this project is 27371159.
b. This capital investment was required due to the condition of the
conduit and the essential need for the coal dumper to allow for the
safe and reliable operation of the plant (the equiprnent is used to
empty the coal cars into the trestle). Additionally, as explained in the
Response to Request No. 6, PGE has had on retainer a contractor
that remains on-site at Boardman to assist in a variety of smaller
projects at the plant, including the electrical work required for the coal
dumper conduit replacement. Given the essential nature of the
equipment and the ability of the contractor on-retainer to perform the
work efficiently, plant personnel made the decision to use the on-site
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
contractor to perform the electrical work. The table below shows the
majority of the charges were recorded as outside services, reflecting
the work performed by the on-site contractor.
c. Please see the response to (b) above. There were no bidder
proposals associated with the coal dumper conduit replacement.
d. Please see the response to (b) above. There were no project
construction documents associated with the coal dumper conduit
replacement.
e. Please see the response to (b) above. There were no project scope,
delay or cost overrun documents associated with the coal dumper
conduit replacement.
f. The following chart summarizes PGE's direct and indirect charges made
for the coal dumper conduit replacement:
lntemal PGE Labor, Gapital Loadings,
Other Miscellaneous Charses $29,941
Materials $11.856
Outside Services $1U.122
100% Total $145,919
g. ldaho Power has recorded $14,592 of investments associated with
the coal dumper conduit replacement, which is the Company's 10
percent share of PGE's costs.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO POI/VER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF . 8
REQUEST NO. 8: For blanket project "PCN094 - Boardman-Purchase Minor
Tools & Equus'identified in Exhibit No. 4 of Adelman, D! Testimony, please provide the
following:
a. Any other project numberc associated with this project either by
the operator Portland General Electric "PGE'or ldaho Power
Company'lPC',
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 overruns
e. PGE indirect and/or direct charges made to the project.
f. IPC indirect and/or direct charges made to the project.
NOTE: \Mrere 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.
RESPONSE TO REQUEST NO. 8: The Purchase Minor Tools & Equipment
project provided in Exhibit No. 4 is a blanket project that is intended to capture the
purchase of tools, equipment and portable electrical instrumentrs that are required to
perform normal construction and/or repair work, which is typically associated with
equipment failures. As can be seen in the document labeled Confidentia! Attachment
- Request No. 13 - AMP - Minor Tools and Equip - Nov 2015, PGE included in its
Asset Management PIan dated November 10, 2015, annual budget amounts to
IDAHO POWER COMPANY'S SEGOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
capture these capital expenditures associated with equipment faitures because, as
Boardman was nearing its end-of-life, fewer planned capital projects were envisioned,
budgeted and scheduled.
This reduction in expected capital spend at the plant to include only those
investments required to maintain functionality, reliability and safety was the genesis
of the blanket project identifications. As such, it is the primary driver of the variance
reflected in Exhibit No. 4 to Mr. Adelman's direct testimony for the blanket project
Minor Tools and Equipment because the majority of these capital expenditures are
associated with unplanned equipment failures and the tools or equiprnent required to
perform the repair work. Equipment failures that were material in nature and required
extensive work were assigned a new project number. However, most minor tool and
equipment purchases were charged to the total blanket project. Annually, tdaho
Power's share of these costs, which include the purchase of 310 pieces of equipment
since 2012, averaged approximately 912,500.
Due to the current gtobal pandemic, and the voluminous nature of confidential and
non-confidential information provided in response to other data requests in this case, the
Company is posting the attachment(s) to this request to the secure FTp site to allow
parties to view the requested information for all data requests, in one place, remotely.
Because certain attachments contain confidential information, the FTp site is password
protected and will only be provided to those parties who have executed the protective
Agreement in this matter. Although the entire set is password protected so that the
responses could be grouped holistically, documents subject to the protective agreement
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRSTPRODUCTION REQUEST OF THE COMMISSION STAFF - 10
are marked 'CONFIDENTIAL.' To gain access to the secure FTP site, please contact
Courtney Waites via email at [e-mail].
a. The PGE Project Number is 35469, 1000001541 or 7000000582. The
ldaho power work order numbers associated with this blanket project are
27405230, 27452714, 2742U31, 27383256, 27500625, 27361901'
27478620 and 27523660'
b. Tools and equipment included in this blanket project classification are a
result of equipment failures and are therefore required for the safe and
reliable operation of the plant. As can be seen in the table below, the
costs included in this blanket project are primarily for the purchase of
the tool or equiPment'
c. please see the response to (b) above. There were no bidder proposals
associated with each individual tool or equipment purchased'
d. Please see the response to (b) above. There were no project
construction documents associated with each individual tool or
equiPment Purchased.
e. please see the response to (b) above. There were no project scope,
delay or cost overrun documents associated with each individualtool or
equiPment Purchased.
f, The following chart summarizes PGE's indirect and/or direct charges
made to the blanket Proiect:
IDAHO PO\IVER COMPANY'S SEGOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF . 11
lnternal PGE Labor, Capital Loadings,
Other M iscellaneous C haroes $33.169
Materials $912.415
Outside Services $23,330
100% Total $968,914
g. ldaho Power has recorded $100,853 of investments in tools and
equipment to electric plant-in-service which includes the Company's 10
percent share of PGE's costs, $96,891, plus $3,962 of additional
charges associated with ldaho Power loadings and AFUDC.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF . 12
REQUEST NO. 9: For blanket project "P24067 - Boardman - lnstall Platforms"
identified in Exhibit No.4 of Adelman, DlTestimony, please provide the following:
a. Any other project numbers associated with this project either by
the operator Portland General Electric'PGE'or ldaho Power
Company'lPC".
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 vercus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contrac'tor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost overruns
t. PGE indirect and/or direct charges made to the project.
g. lPC indirect and/or direct charges made to the project.
IDAHO POWER COMPANY'S SECOND PARTTAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF . 13
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.
RESPONSE TO REQUEST NO 9: The Install Platforms detailprovided in Exhibit
No. 4 is a blanket project, or a project identification that is intended to capture capital
issues that arise, this one specific to platforms for the safety of plant employees. The
expenditures classified in the lnstall Platforms blanket project are costs associated with
the installation of platforms that allow for the sab access by employees to equipment
within the plant. The original design of the ptant focused on minimizing the footprint to
reduce construction costs, resulting in an arrangement of equipment that required valve
operators to be elevated. As time went on, ergonomic and safety concerns were identified
resulting in the request for platforms to provide plant personnel sa6 access to various
portions of the plant. As can be seen in the document labeled ConfidentialAttachment
- Request No. I - AMP - lnstall Platforms - Nov 2015, PGE included in its Asset
Management Plan dated November 10, 2015, annual budget amounts to capture
these safety issues that arise.
Due to the current global pandemic, and the votuminous nature of confidential and
non-confidential information provided in response to other data requests in this case, the
Company is posting the attachment(s) to this request to the secure FTp site to allow
parties to view the requested information for all data requests, in one place, remotely.
Because certain attachments contain confidential information, the FTp site is password
protected and will only be provided to those parties who have executed the protective
Agreement in this matter. Although the entire set is password protected so that the
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRSTPRODUCTION REQUEST OF THE COMMISSION STAFF - 14
responses could be grouped holistically, documents subiect to the protective agreement
are marked .coNFlDENTlAL.', To gain access to the secure FTP site, please contact
Gourtney Waites via email at [e-mail]'
a. The pGE Project Number is 26899 and24067 and the ldaho Powerwork
order numbers associated with these projects are 27361904 and
27383254.
b. The installation of equipment platforms is required for the safety of
Boardman employees, thus necessitating this capital investment.
Additionally, as described in the Response to Request No. 6, PGE
has had on retainer a contractor that remains on-site at Boardman to
assist in a variety of smaller projects at the plant, including the
installation of platforms. Due to the urgency and minor complexity of
the work required, plant personnel made the decision to use the on-
site contractor to instatl the platforms. The charges for the work
performed by the on-site contractor can be seen in the chart below,
labeled "Outside Services".
c. please see the response to (b) above. There were no bidder
proposalsassociatedwiththeplatforminsta|lations.
d. please see the response to (b) above. There were no project
construction documents associated with the platform installations'
e. please see the response to (b) above. There were no project scope,
delay or cost overrun documents associated with the platform
installations.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 15
f. The following chart summarizes PGE's direct and indirect charges
made for the installation of platforms:
lnternal PGE Labor, Gapital Loadings,
Other Miscellaneous Charges $9.230
Outside Services $119.750
100o/o Total $128,980
g. ldaho Power's direct and indirect charges include the Company's 10
percent share of PGE's charges, $12,898, plus an additional $292
associated with the Company's loadings and AFUDC, for a total of
$13,190.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE GOMMISSION STAFF . 16
REOUEST NO. .l0: For blanket project "P35591 - As-Built Drawings - Generation"
identified in Exhibit No. 4 of Adelman, DlTestimony, please provide the following:
a. Any other project numbers associated with this project either by
the operator Portland General Electric'PGE'or ldaho Power
Company'lPC'.
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 stratus 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. IPG indirect and/or direct charges made to the project.
IDAHO POVVER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 17
NOTE: \Mrere 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.
RESPONSE TO REQUEST NO. ,l0: As-built documentation is the process in
which drawings used to implement a design are revised to reflect the true condition, or
the as-built condition. This continuous process also documents the actual field conditions
as plant personnel identify changes not captured in the existing drawings. For example,
an operator may see a valve in place where a drawing doesn't show the valve, The
operator will notify engineering and the drawing is updated. The resulting work by PGE
personnel is charged to the plant under the As-Built Drawings blanket proiect.
a. PGE assigned the blanket project P35591 - As-Built Drawings -
Generation project numbers 1000003025 and 1000003028. The ldaho
Power work order numbers are 273780'18, 27383258, 27405232,
27 42U32, 27 4527 1 5, 27 47 8622, 27 500627, and 27 5236 56.
b. As-built documentation is a continuous process in which expenditures
occur when modifications are made to the plant or when plant
personnel identify an incomplete drawing and drawings must be
updated to reflect actual conditions of the plant. The work is done
internally by PGE's engineering department so no analysis to support
the as-built drawing investments was done. lnstead, because the
work is done internally, the result is the lowest-cost alternative
available.
IDAHO POI/VER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
c. PIease see the response to (b) above. There were no bidder
proposals associated with the as-built drawings.
d. Please see the response to (b) above. There were no project
construction documents associated with the as-built drawings.
e. Please see the response to (b) above. There were no project scope,
delay or cost overrun documents associated with the as-built drawings.
f. The following chart summarizes PGE's direct and indirect charges made
for the as-built drawings:
lnternal PGE Labor, Capital Loadings,
Other Miscellaneous Charoes $362.813
Outside Services $22,352
100% Total $385,165
g. ldaho Power has recorded $38,548 of investments in the as-built
drawings to electric plant-in-service which includes the Company's 10
percent share of PGE's costs, $38,517, plus $31 of additional charges
associated with ldaho Power loadings and AFUDC.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, Idaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 19
REOUEST NO. 1{: For project "BART-Bdmn Air Quality Controls" identified in
Exhibit No. 4 of Adelman, Dl restimony, please provide the following:
a. Any other proiect numbers associated with this project either by
the operator Portland General Electric "pGE'or ldaho power
Company'lPC'.
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 tist(s)
vii. Contractor change order requests
e. Project correspondence discussing:
i. Project change in scope
ii. Project delay
iii. Project cost overruns
t. PGE indirect and/or direct charges made to the project.
g. IPC indirect and/or direct charges made to the project.
IDAHO POWER COMPANY'S SEGOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 20
NOTE: \Mrere requested information has not been provided, please explain why
it was not provided. Pbase also explain how the Company is assured construction of
the proiect is at least cost.
TO NO. 1,l:The Best Available Retrofit Technology
("BART') air quality control project was one of the two investments made at Boardman
since June 1 ,2112,that was for environmental compliance. Although the Environmental
Protection Agency approved a2O2O Boardman shut-dorrrn, through the BART rulemaking
prooess, the Oregon Regiona! Haze State Implementation Plan ("RHS!P') and per the
Oregon Department of Environmental Quality Title V Operating permit and Acid Rain
permit, SO2 emissions were still required to be controlled and monitored. This project,
which was the lowest cost option, included the addition of a dry sorbent injection system
to control sulfur emissions from Boardman, as required by BART and the Oregon RHSIP.
At the time, SO2 emissions were approximately 0.90 lb/MMBtu on a 3O-boiler operating
day rolling average, above the emissions limit of 0.40/lb/MMBtu by July 1,2014, and 0'30
lb/MMBtu by July 1, 2018. The alternative was to install either a wet or dry scrubber
system, but both these options were more costly and could not be installed in time to meet
the July 1,2014 deadline. The dry sorbent iniection system investment included a lower
capita! cost and shorter design and installation period as compared to alternative
investments.
Due to the votuminous nature of the documents provided in response to this
request, the mix of confidential and non-confidential information provided by the plant
operator, and to aid in the parties' review by providing one complete set of information,
the Company would typically make these documents available for on-site review.
TDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 21
However, due to the current global pandemic and safety @ncerns associated with an on-
site review, the Company has posted these attiachments to a secure FTp site to allow
parties to view the requested information remotely. Because certain attachments contain
confidential inforrnation, the FTP site is password protected and will only be provided to
those parties who have executed the Protective Agreement in this matter. Although the
entire set is password protected so that the responses coutd be grouped holistically,
documents subject to the protective agreement are marked "CONFIDENTIAL., To gain
access to the secure FTP site, please contiact Courtney Waites via email at
arua ites@ idahooower.com.
a. The PGE project Numbers are26444,26ms,2d446,26u7,26ug,26mg,
35229, 1 000001 58 4 or 1000001 760. The ldaho Power work order numbers
associated with this project are 27324967, 27324969, 27324969,
27 32497 O, Zl gg917 4, 27 9i1g06, and Zl 969452.
b. Please see the file labeled Confidential Attachment - Request No. 11b
for the preliminary funding request, detailing the justification for the
project.
c. Please see the file labeled Confidential Attachment - Request No. 11c
for the bidder selection justification. Also included is Attachment -
Request No. 11c, the Request for Qualifications for the EpC Contractor
for the dry sorbent injection system installation.
d. Please see the confidential and non-confidential files labeled
Attachment - Request No. 11d for project construction documentation
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FTRSTPRODUCTION REQUEST OF THE COMMISSION STAFF - 22
including the preliminary engineering report and the key process
diagrams, controls key plan, electrical load list and list of vendors.
There were no project scope, delay or cost overrun documents
associated with the BART air quality control proiect.
The fotlowing chart summarizes PGE's direct and indirect charges made for
the BART air qualiff contro! project beginning June 1 ,2012:
lnternal PGE Labor, Ca
Miscellaneous Charges
pita! Loadings, Other
$11.383,306
Materials $539,663
Outside Services $22424.390
100% Total $34.347.359
ldaho Power has recorded $2,817,269 of investments associated with
the BART air quality control project to electric plant-in-service included
in the balancing account since June 1, 2012. Because this project
spanned multiple years, both prior to the establishment of the Boardman
balancing account and after, the Company is still in the process of
reconciling PGE's charges with those recorded by ldaho Power. The
Company will provide an update to the Commission when this
reconcaliation is complete prior to the initial comment deadline in this
case
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power ComPanY.
IDAHO POVVER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 23
e
f.
g
REQUEST NO. 13: For project'BN - Misc. Pumps. Valves, Motors'identified in
Exhibit No. 4 of Adelman, Dl Testimony, please provide the following:
a. Any other project numbers associated with this project either by
the operator Portland General Electric "PGE'or ldaho Power
Company "lPC'.
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 stratus 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.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.24
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.
RESPONSE TO REQUEST NO. 13: The purpose of the Miscellaneous Pumps,
Valves, and Motors blanket project is to capture capital expenditures necessary when
unexpected failures occur at the plant. These are expenditures that are necessary to
maintain functionality, reliability and the safety of the plant and are less than $30,000
each. Similar to the minor tools and equipment investments explained in the Company's
Response to Request No. 8, PGE included in its Asset Management Plan dated
November 10,2015, annual budget amounts to capture these capital expenditures
associated with unexpected failures because, as Boardman was nearing its end-of-
!ife, fewer planned capital projects were envisioned, budgeted and scheduled. See
Confidential Attachment - Request No. 13 - AMP - Misc Pumps, Valves, Motors -
Nov 2015.
This reduction in expected capital spend at the plant to include only those
investments required to maintain functionality, reliability and safety was the genesis
of the blanket pQect identifications. As such, it is the primary driver of the variance
reflected in Exhibit No. 4 to Mr. Adelman's direct testimony for the blanket project
Miscellaneous Pumps, Valves, and Motors because the majority of these capita!
expenditures are associated with unplanned investments. When a capital issue arose
that was materia! in nature, it was assigned a new project number, but if it was
expected to cost less than $30,000, as most associated with pumps, valves and
motors are, the expenditures were charged to the blanket project.
IDAHO POVVER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.25
Due to the current global pandemic, and the voluminous nature of confidential and
non-confidential information provided in response to other data requests in this case, the
Company is posting the attachment(s) to this request to the secure FTP site to allow
parties to view the requested information for all data requests, in one place, remotely.
Because certain attachments contain confidential information, the FTP site is password
protected and will only be provided to those parties who have executed the Protective
Agreement in this matter. Although the entire set is password protected so that the
responses could be grouped holistically, documents subject to the protective agreement
are marked 'CONFIDENTIAL.' To gain acoess to the secure FTP site, please contact
Courtney Waites via email at [e-mail].
a. PGE assigned the blanket project Miscellaneous Pumps, Valves, and
Motors project numbers P23260,P35214, and 1000001549. The ldaho
Power work order numbers are 27361898, 27383257, 27405228,
27 428430, 27 4 527 1 3, 27 47 8623, 27 5 0 06 26, and 27 5236 5 9.
b. This blanket project number captures only those expenditures
associated with investments under $30,000 that are required to
maintain functionality, reliability and the safety of the plant. As reflected
in the table of expenditures below, the majority of the costs are
associated with the direct purchase of miscellaneous pumps, valves,
and motors or outside services employed for the installation of the
equipment. The plant generally engages the on-site contractor described
further in the Company's Response to Request No. 6 for these smaller
jobs related to the miscellaneous pumps, valves and motors installations
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.26
because the contractor on retainer can efficiently and quickly perform
the work.
c. Please see the response to (b) above. There were no bidder
proposals associated with the miscellaneous pumps, valves and
motors investments.
d. Please see the response to (b) above. There were no project
construction documents associated with the miscellaneous pumps,
valves and motors investments.
e. Please see the response to (b) above. There were no project scope,
delay or cost overrun documents associated with the miscellaneous
pumps, valves and motors investments.
f. The following chart summarize PGE's direct and indirect charges made
for the miscellaneous pumps, valves and motors:
lnternal PGE Labor, Capital Loadings,
Other Miscellaneous Charoes $314,828
Materials $1 .191 ,033
Outside Services $777.046
1o0o/o Total $2.282,s07
g. ldaho Power has recorded $236,620 of investments in miscellaneous
pumps, valves and motors to electric plant-in-service which includes
the Gompany's 10 percent share of PGE's costs, $228,291, plus
$8,329 of additional charges associated with ldaho Power loadings
and AFUDC.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.27
DATED at Boise, ldaho, this 26th day of October 2020.
,f* !.7/"t-t,-^,
LISA D. NORDSTROM
Aftorney for ldaho Power Company
IDAHO POVVER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.28
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26h day of October 2020,1 served a true and
correct copy of IDAHO POWER COMPAiIY'S SEGOND PARTIAL RESPONSES TO
THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon the
following named parties by the method indicated below, and addressed to the bllowing:
Gommission Staff
John R. Hammond, Jr.
Deputy Attorney General
11331 W. Chinden Blvd., Suite 201-A
Boise, ldaho 83714
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 N. 6th Street
Boise, ldaho 83702
_ Hand Delivered
_U.S. Mail
_Overnight Mail
_F$(X Email [e-mail]
_Hand Delivered
_ U.S. Mail
Overnight Mail
_FA)(X Emai! [e-mail]
Stephanie Buckner, Executive Assistant
IDAHO POVVER COMPANY'S SECOND PARTIAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.29