20220322Staff 4-31 to IPC.pdf

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luAR 2 2 2022
TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 11542
Boise, ldaho
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPAII'Y'S APPLICATION FOR A
DETERMINATION VALIDATING THE
NORTH VALMY POWER PLANT
BALANCING ACCOUNT TRUE.UP.
CASE NO.IPC-E-22-05
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
STAFF of the Idaho Public Utilities Commission, ("Staff') by and through its attorney of
record, Taylor Brooks, Deputy Attomey General, hereby requests that Idaho Power Company
provide the following documents and information as soon as possible, but no later than
TUESDAY, APRrL 12, 2022.
This Production Request is continuing, and Idaho Power 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER
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I MARCH 22,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 4: Please explain the timing of the Company's plan to update
decommissioning costs attributed to the North Valmy Plant. If the Company has no plan to
update the decommissioning costs, please explain why not and any potential implications to
customers.
REQUEST NO. 5: What equipment, parts, or other infrastructure can the Company
salvage from Unit No. I to use in Unit No. 2.
REQUEST NO. 6: Please provide documentation showing when NV Energy ('NVE")
plans to exit Unit No. I and Unit No. 2 operations at the North Valmy Power Plant.
REQUEST NO. 7: Please explain the physical limitations of extending Unit No. 2
operations beyond the end of2025.
REQUEST NO. 8: Please explain if the Framework Agreement allows operation of Unit
No. 2 beyond the end of 2025. If so, please provide the specific language in the Agreement and
the costs agreed to by both parties associated with extending operations in order to contribute to
meeting Company load.
REQUEST NO. 9: Please provide documentation showing how the Company and NVE
"... work jointly to make decisions regarding Valmy" regarding investments made at the North
Valmy Plant during the period from January 1,2019, through to December 31,2021
(BARRETTO, DI3).
REQUEST NO. 10: In Barretto, DI, page 5, it states, "... ldaho Power has established
guidelines at Valmy to allow NV Energy to manage the capital budget as needed and directed by
the plant manager, without exceeding the yearly budget, or adding large projects without
authorization by the Parties," and goes on to say, "These guidelines provide the appropriate level
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 22,2022
of oversight while allowing the plant operator to practically manage the plant and any variances
that may occur throughout the budget year." Please provide the following:
a. Please provide the agreed upon guidelines and include a history of any revisions.
b. Please quantiff "large projects."
c. Please explain the purpose of each of the guidelines and explain how it contributes to
providing the appropriate level of oversight.
RBQUEST NO. 11: Please provide documentation used in preparation for or used
during the Ownership Meetings or other partner meetings where individual capital project
variances were considered or discussed between the Parties with respect to North Valmy capital
investments that were made during the period from January 1,2019, through to December 31,
2021.
REQUEST NO. 12: For all capital projects between the period from January 1,2019,
through to December 31, 2021, please provide documentation reflecting the signed Authorization
for Expenditures ("AFE"). (BARRETTO, DI 6).
REQUEST NO. 13: In Barretto DI, page 6, it indicated that "Currently Idaho Power
provides authorization to NV Energy of all AFEs and supplemental AFEs for each project.
Idaho Power has requested that no projects begin, and the budget may not be exceeded, unless
the AFE is approved by both NV Energy and Idaho Power." Please provide the date and explain
the circumstances under which this policy was created.
REQUEST NO. 14: Please list and describe the Company's process steps for assessing
a "holistic budget review". (BARRETTO, DI 7).
REQUEST NO. 15: Please provide a detailed description of the process the Company
used to validate and approve costs incurred by its managing partner, NVE.
REQUEST NO. 16: For each capital project contained in EXHIBIT NO. 2 from January
1,2019, through December 31,2021, with an Idaho Power share amount of $150 thousand or
SECOND PRODUCTION REQUEST
TO IDAHO POWER J MARCH 22,2022
greater, please provide the Company's due diligence analysis with supporting workpapers to
show that the project was managed to achieve least cost. Specific to each project, please include
analysis showing that:
a. The overhead costs for NVE to provide project management and oversight were
verified as correct and prudently incurred;
b. The costs for completing projects using NVE direct labor and materials were verified
as correct and prudently incurred;
c. The costs from NVE's project contractor and/or subcontractors were verified as
correct and prudently incurred; and
d. The costs for equipment procured by NVE were verified as correct and prudently
incurred.
REQUEST NO. 17: Please provide the cost justification for purchasing freeze
protection heaters instead of continuing to rent portable electric space heaters. (BARRETTO, DI
l0).
REQUEST NO. 18: Please provide all documentation assessing the failure of the Unit
No. I pulverizer (lD) as well as any inspection reports prior to the failure. (BARRETTO, DI
13).
REQUEST NO. 19: Please explain what is meant by the Unit No. I pulverizer "had
been experiencing much higherthan-expected availability requirements". (BARRETTO, DI 13).
REQUEST NO. 20: Please explain why the Unit No. 1, (1D) pulverizer exceeded
20,000 hours of operation prior to identifuing the significant wear and parts that had deteriorated
beyond the service life expectations. (BARRETTO, DI 13).
REQUEST NO. 21: Did the downtime on the Unit No. 1, (lD) pulverizer, cause any
downtime or reduced output on Valmy Unit No. I ? If so, please provide a record of the
downtime, the amount of lost electricity generation, and the additional cost to the Company due
to the downtime.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 MARCH 22,2022
REQUEST NO. 22: Please provide details and analysis explaining the Unit No. I
circulating water pump failure due to the ground fault. (BARRETTO, DI l5).
REQUEST NO. 23: Please provide details and analysis explaining the Unit No. I (1A)
primary air fan motor damage. (BARRETTO, DI 16).
REQUEST NO. 24: In BARRETTO, DI, Exhibit No. 2, Page I of 3, Please explain the
timing and replacement for the overall large number of atomizer wheel replacements attributed
to Valmy Unit No. 2 projects identified as:
a. 27533137 - VALMY 98455854 V2 ATOMIZER WHEELS, REPL,
b. 27579441- VALMY 98485333 V2 SCRUBBER ATOMIZER WHEELS, R, and
c. 27557530 - VALMY 98473784 V2 SCRUBBERATOMIZER WHEELS, R.
REQUEST NO. 25: Please provide the root cause analysis for the "run time failure"
related to project 27570622 - VALMY 98481652 VC 58 COAL UNLOAD CONVEYER BELT,
REPLACE VA. (BARRETTO, DI Exhibit No. 2, page2 of 3).
REQUEST NO. 26: Please provide evidence that the replacement of the gearbox related
to project 27570622 - VALMY 98481652 VC 58 COAL LINLOAD CONVEYER BELT,
REPLACE VA. was implemented in a cost-effective manner (BARRETTO, DI Exhibit No. 2,
page2 of 3).
REQUEST NO. 27: In reference to project 27534969 - VALMY 98455853 V2
PULVERIZER MOTOR 2D, REBUILD, are 600 HP pulverizer motors common and
interchangeable between Unit Nos. I md2?
REQUEST NO. 28: For project'27574743 - VALMY 98482392 V2 REPLACE
TURBINE HP/IP SECTION" identified in Exhibit No. 2 of Barretto, DI, please explain how the
project was completed at least cost. In addition, please provide the following (where requested
information has not been provided, please explain why it was not provided):
SECOND PRODUCTION REQUEST
TO IDAHO POWER 5 MARCH 22,2022
a. All other project numbers associated with this project either by the operator NVE or
the Company.
b. The analysis used to support the capital investment.
c. Bidder proposal requests.
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. NVE indirect and/or direct charges made to the project.
g. Company indirect and/or direct charges made to the project.
REQUEST NO. 29: For project "27514784 - VALMY 98438396 VC FREEZE
PROTECTION HEATERS," identified in Exhibit No. 2 of Barretto, DI Testimony, how the
project was completed at least cost. In addition, please provide the following (where requested
information has not been provided, please explain why it was not provided):
a. All other project numbers associated with this project either by the operator NVE or
the Company.
b. The analysis used to support the capital investment.
c. Bidder proposal requests.
d. Bidder proposal responses.
e. Project construction documentation including, but not limited to:
i. Construction contract
ii. Scope document
SECOND PRODUCTION REQUEST
TO IDAHO POWER 6 MARCH 22,2022
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
f. Project correspondence discussing:
viii. Project change in scope
ix. Project delay
x. Project cost ovemrns
g. NVE indirect and/or direct charges made to the project
h. Company indirect and/or direct charges made to the project
REQUEST NO. 30: Please provide the work order jackets and source documents for the
following projects:
Proiect Description Total
27574743
VALMY 98482392 V2 REPLACE TURBINE HPiIP
SECTION $ 1.240.965
27514784
VALMY 98438396 VC FREEZE PROTECTION
HEATERS s 541,325
27555279
VALMY 98455852 VC GROUND WATER
MONITORING WEL s 219.799
27545751
VALMY 98466935 VI PULVERIZER D ROLL
WHEEL ASS $ 159,459
27539554
VALMY 98467485 V2 SCRUBBER OUTLET DUCT
PLUGGA $ 126,759
27539687
VALMY 98462057 V2 STACK ELEVATOR,
REPLACE $ 107.341
27570622
VALMY 98481652 VC 58 COAL UNLOAD
CONVEYER BELT, REPLACE VA $ 88s.8s3
27551304
VALMY 98453212 V2 SKY CLIMBER
ATTACHMENT PLATFORM, INSTALL $ 31,051
27533t43
VALMY 98459393 Vl 1ST POINT FEEDWATER
INLET VALVE, REFUR $ 14.s64
27502697
VALMY 98434354 Vl LOW NOX BURNER
NOZZLES, REP $13.148
SECOND PRODUCTION REQUEST
TO IDAHO POWER 7 MARCH 22,2022
REQUEST NO.31: Please provide any SOX Compliance Reports and intemal audit
reports with supporting workpapers for the Valmy facility. In addition, please provide the
Valmy Billing Review Audit reports and workpapers for the years 201 8, 2019,2020, and 2021 .
,lDATED at Boise,Idaho, this/2 day of March2022
aylor
i:umisc:prodreq/ipce22.5tbrk prod req 2
SECOND PRODUCTTON REQUEST
TO IDAHO POWER 8 MARCH 22,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF MARCH 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
coMMrssloN STAFF TO IDAHO POWER COMPATIY, IN CASE NO.
IPC.E-22-05, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE