20201109Staff 16-21 to IPC-Redacted.pdf

Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 5470
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
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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CASE NO.IPC.E.2O.32
REDACTED SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
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,
NOVEMBER 23, 2020.r
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
1 Staffis requesting an expedited response. Ifresponding by this date will be problematic, please call Staff's attorney at
(208) 334-03s7.
1 NOVEMBER 9, 2O2O
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3r.u.0r.228.
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. 16: Please provide a detailed description of the process the Company used
to validate and approve costs incurred by its managing partner, Portland General Electric (pGE).
REQUEST NO. 17: For each capital project made from June I,2Ol2, through June 30,
2020, please provide the Company's due diligence analysis with supporting workpapers to show
that the project was managed to achieve least cost and that the resulting costs were reasonable.
Specific to each project, please include analysis showing:
a. The project costs for internal PGE project management, oversight, PGE capital
loadings and associated direct costs by PGE for labor and materials were verified as
correct and prudently incurred;
b. The project costs from PGE's project contractor and/or subcontractors were verified
as correct and prudently incurred; and
c. The project costs for equipment procured by PGE were verified as correct and
prudently incurred.
REQUEST NO. 18: The Company in Response to Production Request No. 15 provided the
file CONFIDENTIAL Attachment - Request No. 15 - Boardman WO Jacket Scans.pdf. On page
261, an email to Cheryl Hobbs notes approval by John Carstensen for setup of three projects into
"passport".
a. Please explain the context of the email requesting and providing approval to setup
the projects into "passport;"
b. Please explain the need for Mr. Carstensen's approval; and
c. Please explain and provide documentation supporting Mr. Carstensen's due diligence
review for approving these projects.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY NOVEMBER9,2O2O2
REQUEST NO. 19: Specific to Production Requests 3(g),4(g), 5(g), 6(g),7(g),8(g)' 9(g),
10(g), 1l(g), l2(g), and 13(g), Staff requested Idaho Power provide "PGE indirect and/or direct
charges made to the project." In response, the Company provided a single amount attributed to
internal PGE labor, capital loadings, employee expenses, and other misc. charges. For each PR
noted above, please provide a breakdown by internal PGE labor, capital loadings, employee
expenses, and other misc. charges and provide original project documentation detailing these costs
by capital project.
REQUEST NO.20: Please explain the difference in amounts between Exhibit No.4
(Exhibit No. 4_Actual vs Budget.xls), Column S "Actuals" and the noted amounts shown in
Response to Production Requests referenced below:
2 Reference CONFIDENTIAL Attachment - Request No. 3 - Boardman Upgrade Fire Protection Reconciliation
3 Reference CONFIDENTIAL Attachment - Request No. 5 - New Fire Detection System Reconciliation
a Reference CONFIDENTIAL Attachment - Request No. 12 - Boardman Replace VSDs Reconciliation
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3
EXHIBIT NO. 4
Project Description
EXHIBIT
NO.4
"Actuals"
Cell
Location
EXHIBIT
NO.4
Actual
Amount
($)
PROD
REQ
#
PR
RESPONSE
Amount
($)
DIFFERENCE
($)
P24688 - Boardman - Upgrade Fire
Protection S7 l,0l1,566 3
-
P26266 - BN-Install New Fire Detection
Sys s14 1,684,486 5 I
P35469 - BN - Replace Coal Dumper
Conduit s22 149,856 7 145,919 3,937
PCN094 - Boardman-Purchase Minor
Tools & Equ s32 1,016,885 8 968,9t4 47,971
P24067 - Boardman - Install Platforms s33 150,701 9 128,980 21,'721
P35591 - As-Built Drawings -
Generation s35 362,378 10 385,165 -22,787
BART-Bdmn Air Quality Controls s15 36,798,917 ll 34,347,359 2,451,558
P35182 - BN - Replace VSDs for ID
Fans s20 3,383,190 12
BN - Misc. Pumps. Valves, Motors S6 2,024,876 t3 2,282,9W -258,031
NOVEMBER9,2O2O
REQUEST NO.21: In reference to Exhibit No.4 (Exhibit No. 4_Actual vs Budget.xls),
please explain why the "Actual" (Column S) amount is significantly higher than the "Total IPC
Budget" (Column T) amount for each of the projects referenced below:
DATED at Boise,Idaho, this
Gl,-l' day of November 2020.
Attorney General
i:umisc:prodreq/ipce20.32jhrk prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4
EXHIBIT NO. 4
Project Description
EXHIBIT
NO.4
Actual
Amount
($)
EXHIBIT
NO.4 Total
IPC Budget
($)
EXHIBIT NO. 4 Variance
(Percentage)
P24688 - Boardman - Upgrade Fire Protection 1,011,566 2t2,340 376Vo
P24806 - BN: Expand Maint & Weld Shops 2,085,547 r,500,000 39%io
P26938 - Boardman - Upgrade Ash Handling Sys 724,258 456,020 597o
P35469 - BN - Replace Coal Dumper Conduit 149,856 50,000 2OO7o
PCN094 - Boardman-Purchase Minor Tools & Equ 1,016,885 504,250 lO2%io
P24067 - Boardman - Install Platforms 150,701 108,000 40Vo
NOVEMBER 9, 2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9th DAY OF NOVEMBER 2020,
SERVED THE FOREGOING REDACTED SECOND PRODUCTION REQUEST
oF THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE
NO. IPC-E-20-32, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 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 D 83702
E-MAIL: botto @ idahoconservation.org
CERTIFICATE OF SERVICE