20220412IPC to Staff 4-31.pdf

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An DACOnP Company
LISA D. NORDSTROM
Lead Counsel
[e-mail]
LDN:sg
Enclosures
April12,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Case No. IPC-E-22-05
ln the Matter of the Application for a Determination Validating the North
Valmy Power Plant Balancing Account True-Up
Dear Ms. Noriyuki:
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho
Power Company's Response to the Second Production Request of Commission Staff.
Due to the voluminous nature of confidential and non-confidential information
provided in response to 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 access to the secure FTP site, please contact Stacy Gust via
email at [e-mail].
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Re
X*!-fl^,ut,.*,
Lisa D. Nordstrom
CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPG-E-22-05
ldaho Power Gompany's Application for a Determination Validating the North
Valmy Power Plant Balancing Account True-Up
The undersigned attorney, in accordance with RP 67, believes that the
Attachments in response to Request Nos. 4, 9, 26, 29, and 31 to ldaho Power
Company's Response to the Second Production Request of the Commission Staff dated
April 12, 2022, may contain information that ldaho Power Company or a third party
claims is confidential as described in ldaho Code S 74-101, ef seg., and $ 48-801, ef
seg., and as such is exempt from public inspection, examination, or copying.
DATED this 12th day of April2022.
fr* !.(^1"+r'.^,,
Lisa D. Nordstrom
Counselfor ldaho Power Company
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ida hopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERM INATION VALIDATING THE
NORTH VALMY POWER PLANT
BALANCING ACCOU NT TRUE.UP.
CASE NO. !PC-E-22-05
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/'or "Company"), and in
response to the Second Production Request of the Commission Staff ("Staff) dated
March 22,2022, herewith submits the following information:
Due to the voluminous nature of confidential and non-confidential information
provided in response to 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 alldata 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
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY - 1
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this matter. Atthough the entire set is password protected so that the responses could
be grouped holistically, documents subject to the protec'tive agreement are marked
'CONFIDENTIAL." To gain aooess to the secure FTP site, please contact Stacy Gust
via email at [e-mail].
IDAHO POWER COMPANYS RESPONSE TO THE SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POV'JER COMPANY.2
REQUEST FOR PRODUCTION NO.4: Please explain the timing of the
Company's plan to update decommissioning costs attributed to the North Valmy Plant.
lf the Company has no plan to update the decommissioning costs, please explain why
not and any potential implications to customers.
ldaho Power does not
have a definitive timeline to update Valmy decommissioning cost estimates. Article lV
of the North Valmy Project Framework Agreement Between Sierra Pacific Power
Company d/b/a NV Energy ("NVE' or "NV Energy") and ldaho Power Company dated
as of February 22,2019 ("Framework Agreemenf'), included as ConfidentialAttachment
1, addresses a remaining party's election to retire a unit or continue operating beyond
December 31,2025. lf the remaining party elects to operate past this date, a Class 2-
Level Decommissioning Study is required to establish the basis of a one-time
decommissioning payment payable by the exiting party for their share. lf parties agree
to cease operating the final unit as of a common date, then each party is responsible for
their share of the actua! cost of demolition, remediation, and decommissioning of the
plant as they are incurred. Under this operating scenario, the contractua! obligation to
conduct a study does not exist.
Given the uncertain timing of when each party will exit participation in operations
at Valmy, and because the Valmy balancing account mechanism approved in Case No.
IPC-E-16-24 allows for the tracking and true-up of levelized revenue requirement
amounts to actua! costs incurred over time, ldaho Power does not believe an update to
the decommissioning costs is warranted or provides value to customers at this time.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REOUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
The response to this Request is sponsored by Randy Henderson, PrincipalJoint
Projects Coordinator, ldaho Power Gompany.
IDAHO POI,\'ER COMPANYS RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPATIY -4
REQUEST FOR PRODUCTION NO. 5: What equipment, parts, or other
infrastructure can the Company salvage from Unit No. 1 to use in Unit No. 2.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: The equipment that can
be salvaged from Unit 1 to use in Unit 2 includes the central air compressors, some
large circuit breakers, the boiler feedpump rotor, fan lube oil pumps, pulverizer lube oil
pumps and clarifier equipment. Because the major components of both units are
products from different manufacturers, the interchange of parts and equipment is
!imited.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 6: Please provide documentation showing
when NV Energy ('NVE") plans to exit Unit No. 1 and Unit No. 2 operations at the North
Valmy Power Plant.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: P|ease see Attachment
1 for the Public Utilities Commission of Nevada's Modified Fina! Order in Docket No. 21-
06001, the Amended Joint Application of Nevada Power Company d/b/a NV Energy and
Sierra Pacific Power Company d/b/a NV Energy for approval of their 2022-2041
Triennial lntegrated Resource Plan, including the Transmission lnfrastructure for a
Clean Energy Economy Plan, and 2022-2024 Energy Supply Plan, indicating an exit of
both units and retirement of the North Valmy Power Plant in 2025.
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 REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 7: Please explain the physical limitations of
extending Unit No. 2 operations beyond the end of 2025.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The following are the
major risks of extending Unit 2 operations past 2025:
o Continued compliance with Nevada's Regional Haze State lmplementation
Plan,
o The risk of running out of evaporation pond capacity,
o The requirement that the plant would need to resume equipment maintenance
such as tu rbine overha u l/inspection and pu lverizer overha u l/inspection,
. The supplemental labor contract would need to be extended.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, Idaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPAiIY -7
REQUEST FOR PRODUCTION NO.8: Please explain if the Framework
Agreement allows operation of Unit No. 2 beyond the end ol2025. lf 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.
RESPONSE TO REQUEST FOR PRODUCTION Ng. 8: Article lV of the
Framework Agreement, included as ConfidentialAttachment 1 to the Response to
Request for Production No. 4, outlines the responsibilities for the parties if one pafi
elects to continue operating a unit beyond December 31,2025, including
decommissioning procedures and decommissioning cost responsibilities, conveyance of
interest, and liabilities.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POIA'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST FOR PRODUCTION 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 December31,2021 (BARRETTO, Dl 3).
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: As stated in Ms.
Barretto's testimony, ldaho Power and NVE work together to manage capital projects
and total budget during Ownership Meetings, budget meetings, and other meetings as
needed. Ownership Meetings are held twice a year, and include discussions such as
safety, fuels, transportation, operations, maintenance, outages, performance, and
always includes discussions regarding operations and maintenance expenses and
capital expenditures. Beginning 2021, ldaho Power requested monthly meetings with
plant and corporate personnel to discuss the same issues typically discussed in
Ownership Meetings but on a more frequent basis. These monthly meetings, identified
as the North Valmy Monthly Budget Review and Update, provide a forum for an open
dialog discussing capital project budgets, variances, scope and need, and year-end
forecasts.
Presentation materials from Ownership Meetings and monthly meetings that
were provided electronically are included as attachments to this response. Due to the
voluminous nature of hard copy presentation materia!, it has not been provided in this
response. However, the material is available for review at the Company's headquarters.
Please contact Tami\Mite at [phone] or Dave Fewkes at [phone] to
schedule a time to review the requested information.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 9
The response to this Request is sponsored by John Carstensen, Joint Proiec.ts
Leader, ldaho Power Gompany.
IDAHO POWER COMPAIIIY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPAiIY - 10
REQUEST FOR PRODUCTION NO. 10: !n Barretto, Dl, 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 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. {O:
a. As described in Ms. Barretto's testimony, if ldaho Power's share of the
capitalforecast is greater than the capital budget by more than $100,000,
the Company will review and may authorize a budget change. ln addition,
all new or unbudgeted Unit 2 or common facility capital projects larger
than $1 million, at the plant level, require a review and authorization in
writing prior to starting the project. Finally, any time an individual Unit 2 or
common facility capital project with a value greater than $1 million, at the
plant level, is expected to exceed the current year original budget by 20
percent or more, ldaho Power will review and authorize the change in
writing prior to starting or continuing. The Company requested NVE follow
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMTSSION STAFF TO IDAHO POWER COMPANY - 11
these procedures to provide additional controls to manage capital projects
at the plant outside of the existing ownership agreements.
b. Large projects are those that have a value of greater than $1 million
(current budget year and at the 100 percent partnership level).
c. These additional controls establish the expected formats for reporting
actual expenditures to the budget, expectations regarding explaining
budget variances, and levels of budget changes that require documented
approvalfrom the non-operating partner before spending moves fonryard.
This process serves as the primary way ldaho Power oversees the
financial activities of the partnership. The level of information reported,
along with the research of variances, drive frequent collaborative
discussions between the partners. These discussions address how to best
handle business factors that come up that require deviations to the budget
plan. ln addition, the process ensures decisions regarding new large
projects are not made unilaterally, while allowing the operating partner the
latitude to manage the overall operations of the plant within certain budget
bandwidths. Providing this latitude to the plant director ensures key
maintenance and operational issues are addressed timely and not held up
waiting for an approvalfor spend that is not material or can be absorbed
within the existing operating budget.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST FOR PRODUCTION NO. ,l1: Please provide documentation used in
preparation for or used during the Ownership Meetings or other partner meetings where
individual capita! 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: Please see the
Response to Request for Production No. 9 for the presentation material used during the
Ownership Meetings or other partner meetings.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO PO\'\'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.l3
REQUEST FOR PRODUCTION NO. 12: For all capita! 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).
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: As described in the
direct testimony of Company witness Ms. Barretto, ldaho Power has established
guidelines at Valmy to allow NVE 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 both parties. For all capital projects, NVE produces an AFE
that includes the project title, date, project manager, description and purpose of the
expenditure, cost and budget information, along with various other information to
provide support for the project. Attachments 1 through 45 include the AFE's for al!
those projects for which ldaho Power's ownership share is over $20,000, and all
investments associated with Unit 1. The following chart provides the AFE project code
assigned by the plant for each ldaho Power work order for reference:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 14
Proiect Descr AFE Proiect Code
27574743 VALMY 98/,82392 V2 REPLACE TURBINE HP/IP SECTION vA2235
27514784 VALMY 98438396 VC FREEZE PROTECTION HEATERS,v42140
27517151 VALMY 98438233 VC FIRE PROTECTION SYSTEM. REF vA2139
27528897 VALMY 98455128 V2 PIN MIXER/UNLOADER. REBUILD vA2156
27555279 VALMY 98455852 VC GROUND WATER MONITORING WEL vA2158
27527353 VALMY 98438400 V2 GENERATOR BUSHINGS. REPLACE vPc.144
27547460 VALMY 98377358 V2 PULVERIZER "A'' MAJOR REBUILD-20.16 V4516
27545751 VALMY 98466935 V1 PULVERIZER D ROLL WHEEL ASS vM210
27591516 VALMY 98494358 VC EQUIPMENT WASH PIPING REPLACEMENT vAa250
275495il VALMY 98467485 V2 SCRUBBER OUTLET DUCT PLUGGA vA2166
27533137 VALMY 98455854 V2 ATOMIZER WHEELS. REPL vA2160
27579441 VALMY 98485333 V2 SCRUBBER ATOMIZER WHEELS. R v42189
27557530 VALMY 9e47378/. V2 SCRUBBER ATOMIZER IA/I-IEELS. R vA2185
275396A7 VALMY 98/,62057 V2 STACK ELEVATOR. REPLACE vM207
27570622
VALMY 98481652 VC 58 COAL UNLOAD CONVEYER BELT,
REPLACE VA v42168
27555276 VALMY 98466597 VC VANS. REPLACE (3) VA vA2103
27506993
VALMY 9U3732O VC UNIT SUB 5A 58 1OOO I(/A DRY
TRANSORMER RPL vM't43
27568576
VALMY 98478100 V2 TRISECTOR AIR HEATER EXPANSION JOINT
REFUR vM215
275331M
VALMY 98459394 Vl CIRCULATION WATER PUMP 1A MOTOR,
REPL v42180
27533145
VALMY 98459395 V1 D1 PULVERIZER ROLL WHEEL ASSEMBLY,
REPL vA2181
275y969 VALMY 98455853 V2 PULVERIZER MOTOR 2D. REBUILD v42159
27587933
VALMY 98492604 V2 CONDENSATE PUMP CAPITAL SPARE
INSTALLATION vM243
27556791 VALMLY 98r'73/,62 VAL DMZ SERVER CLUSTER VA vA22',t3
27539686 VALMY 98459449 V1 1A CIRCULATING WATER PUMP M vA2205
2753/.970 VALMY 9U58824 V2 AUXILIARY STEAM DESUPERHEAT v^2167
27il7697 VALMY 98468760 V1 PRIMARY AIR FAN A MOTOR RE vM212
2755',t304
VALMY 98/.53212 V2 SKY CLIMBER ATTACHMENT PLATFORM,
INSTALL v42151
27531065 VALMY 9U54279 VALMY TECHNOLOGY SECURITY UPDA v42161
27577136 VALMY 98485331 VC EDI MODULES. REPLACE 2 v42187
27579435 VALMY 98486141 VC SYSTEM1 UPDATE vM228
27543734 VALMY 98464825 V1 FLY ASH BLOIA/ER 18, REPLACE vA2208
27539690 VALMY 98463011 V2 LIME TRANSFER BLO\A/ER 28. RE vA2'169
27566786 VALMY 98475628 VC RO MEMBRANES. REPLACE 68/32 v41016
27533143
VALMY 98459393 V1 1ST POINT FEEDWATER INLET VALVE,
REFUR vA2'.t77
27502697 VALMY 98434354 V1 LOW NOX BURNER NOZZLES. REP vA2138
27537123 VALMY 98459139 V1 REVENUE METER, UPGRADE v42163
27533147
VALMY 98459448 V1 1ST POINT HEATER EXTRACTION STEAM
BLOCK VA vPQ.178
27501116 VALMY 9U27786 V1 PULVERIZER "B'MAJOR REBUILD VAs16
27502692 VALMY 98434198 V1 SORBENT TRAP MERCURY MONITO VFQ,1U
27528895 VALMY 98/.55'127 V2 CONDENSER INLET WA R vM152
Starting in 2019, the Company began providing authorization to NVE for all
AFEs. This was implemented to provide an additiona! layer of review and consideration
of capital projects as the Company's exit from Unit 1 was approaching. This was
discussed in the October 2019 Ownership Meeting and implemented into the NVE AFE
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 15
approval process soon after. Attachments 46 through 65 are the records documenting
the Company's approval of the AFEs following implementation of the approva! process.
During the budget approval process for the next calendar year, NVE presents
the proposed budget for the plant. The Company will review the proposed budget and
initiate discussions between the partners on the appropriate projects for the next year to
ensure continued safe, reliable operations. There were no capital projects with a value
greater than $1 million at the plant level, that exceeded the original budget by 20
percent for which the Company provided written authorization prior to starting or
continuing the project.
The response to this Request is sponsored by Lindsay Barretto, 500 kV and Joint
Projects Senior Manager, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY - 16
REQUEST FOR PRODUCTION NO. 13: ln Barrefto Dl, page 6, it indicated that
"Currently ldaho Power provides authorization to NV Energy of all AFEs and
supplementalAFEs for each project. ldaho Power has requested that no projects
begin, and the budget may not be exceeded, unless the AFE is approved by both NV
Energy and ldaho Power." Please provide the date and explain the circumstances
under which this policy was created.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: This verbal request
was made by ldaho Powe/s Joint Projects Leader to NV Energy's Generation Executive
in 2O19 during discussions regarding the capital budget and was implemented to
provide an additional layer of review and consideration of capital projects as the
Company's exit from Unit 1 was approaching.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO PO\A'ER COMPANY - 17
REQUEST FOR PRODUCTION NO. 14: Please list and describe the
Company's process steps for assessing a "holistic budget review". (BARRETTO, Dl 7).
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: ldaho Power works
closely with NV Energy and the plant to develop a list of budgeted projects for the
upcoming year and over the plant's remaining life for planning purposes. However, prior
to committing to capital spend on a project, ldaho Power will approve or deny the
project commencement based on the relevant facts and analysis available at that time.
As the units near the end of their planned life, a less static view of the budget has
expanded to one that fully considers other potential ways to extend the life of existing
equipment, while stil! providing safe and reliable service and maintaining environmental
compliance. For example, a decision will balance a traditional capital project
replacement versus partial repairs, or a lease versus a replacement. Planned and
unplanned projects are given the same level of scrutiny. Valmy's capital budget is
managed while maintaining environmentalcompliance and ensuring the operation of the
plant is performed in an economical and safe manner.
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 REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 18
REQUEST FOR PRODUCTION NO. 15: Please provide a detailed description
of the process the Company used to validate and approve costs incurred by its
managing partner, NVE.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: The following details
the process for which ldaho Power validates and approves costs incurred by its
operating partner, NVE:
. On the third business day of each month, NVE uploads the prior month
preliminary cost data file to the Company's secure FTP site for ldaho
Power's accrualentry:
o Check operations and maintenance ("O&M") invoice pivot totals for
the correct ownership share calculations.
o Veriff capital projects for applicable unit and ownership share.
o Compare billing totals to budget and/or budget update.
o Joint Venture Analyst will reach out to Joint Projects team or NVE
with questions, as needed.
. Monthly, NVE emails the ldaho Fuel and O&M invoices, and uploads the
prior month finalized cost data file to the Company's secure FTP site.
o Veriff ldaho O&M invoice pivot in Excel Bl-Data file:
o Compare account totals to prior month accrual, reaching out to
NVE with questions on notable differences.
o Review ldaho O&M invoice pivot for variances, ensuring costs are
billed at correct ownership share of 50 percent or 32.2 percent, per
Framework Agreement.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 19
a
o Check variances if a correcting entry is expected from the prior
month. Reach out to NVE with questions as needed.
o Create a pivot table of the Capital Costs from Bl data. Lookup
ldaho Power's work order and veriff ownership share. For new
capital projects, gather AFE's received from NVE. Using
information from AFE, create work order in Asset Suite and forward
to Joint Projects Leader for review and approval.
o Veriff amounts for ldaho O&M in the pivot agree with ldaho O&M
invoice.
Veriff Fuel invoice pivot in Excel Bl-Data file:
o Compare account totals to prior month accrual, reaching out to
NVE with questions on notable differences.
o Veriff train lease costs tie to what was agreed upon for the current
month.
o Verify diesel costs agree to the subledger provided by NVE.
Subledger tracks the dieseltank balances. Verify ldaho Power's
ownership share at 50 percent of these costs.
o Veriff amounts for Fuel in the pivot agree with ldaho Fuel invoice.
Create and send payment request, with ldaho Fueland O&M invoices, to
Joint Projects Leader requesting the following:
o A review of the invoice and EFT and to forward the email with
approval to Accounts Payable:
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 20
r The approver receives the email, conducts their review of
the invoice(s), then forwards the emailto
![e-mail]. The email must contain a
statement of verification that the work was done, and the
charge is accurate, and approve the attached invoice.
o lf the invoices are more than $500,000, the Joint Projects Senior Manager
is also required to approve the invoice, consistent with the above.
. Account reconciliations are performed monthly on the accounts that the
invoice is recorded. lf any errors are made through the recording of the
invoice, it is discovered and corrected through the reconciliation process.
. Actual to budget results are reviewed monthly with the Joint Projects team
and with NVE operations and finance personnel.
The response to this Request is sponsored by Anne Wadsworth, Joint Venture
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 21
REQUEST FOR PRODUCTION NO. 16: For each capita! project contained in
EXHIBIT NO. 2 from January 1,2019, through December 31,2021, with an ldaho
Power share amount of $150 thousand or 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: ldaho Power does not
prepare an analysis for each capital project veriffing every charge associated with a
project. Rather, the Company has several processes in place in which the prudence of
charges is reviewed. First, invoices are received monthly from NVE billing ldaho Power
for its ownership share of labor, materials, contractor charges and overheads incurred
on capital projects. Part of the invoice review and approval process, as described in
the Response to Request for Production No. 15 includes ensuring the charge category
and total project cost are in line with the latest forecast for that project, and the project
payments are charged at the correct ownership percentage. Because ldaho Power is
not the partner paying the contractors, suppliers, employees, etc. who work and provide
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMM]SSION STAFF TO ]DAHO POWER COMPANY - 22
services on the projects, it is not feasible to perform a separate review/approval of the
payments for these items. ldaho Power relies on budget review activities and controls
to monitor capital spend, ensuring it is prudently incurred, valid and reasonable. As
explained in more detail in the Response to Request for Production No. 31, operational
audits are also performed by ldaho Power's internal audit department annually to
provide further assurance that Valmy capital charges are valid and accurate, and billed
to ldaho Power appropriately.
Further, the Response to Request for Production No. 9 discusses the current
monthly review process whereby the operating partner provides a capitalworksheet
with all current year capital projects with monthly actuals and forecast spend, a
worksheet for forecasted year-end variances for each capital project, and a monthly
variance worksheet for the projects. ldaho Power monitors and reviews the capital
project expenditures and variances through these processes along with
communications with the plant and plant site visits as needed.
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 REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.23
REQUEST FOR PRODUCTION NO. 17: Please provide the cost justification for
purchasing freeze protection heaters instead of continuing to rent portable electric
space heaters. (BARRETTO, Dl 10).
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: PIease see
Attachments 2 and 3 to the Company's Response to Request for Production No. 12for
the AFE's that include the cost justification supporting the installation of the freeze
protection heaters. The cost benefit analysis begins on page 9 of each attachment.
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 REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY .24
REQUEST FOR PRODUCTION NO. l8: Please provide alldocumentation
assessing the failure of the Unit No. 1 pulverizer (1D) as well as any inspection reports
prior to the failure. (BARRETTO, DI 13).
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: Please see
Attachment 1 for the documentation supporting assessment of the failure and inspection
of the pulverizer.
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 REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 25
REQUEST FOR PRODUCTION NO. 19: Please explain what is meant by the
Unit No. 1 pulverizer "had been experiencing much higher-than-expected availability
requirements'. (BARRETTO, DI 13).
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Unit 1 was
experiencing higher than expected availability due to favorable market conditions and
system needs. Originally the unit was expected to be used for summer only operations
and in long-term layup during the remaining months of the year, however, it was utilized
more than anticipated, primarily due to the impacts of the Enbridge pipeline explosion
that occurred in October 2018. The extended run time amounted to many more hours
in operation. Additionally, depending on the coal being burned, all four pulverizers were
occasionally required to achieve full load, as needed for quarterly environmental testing.
The response to this Request is sponsored by Lindsay Barretto, 500 kV and Joint
Projects Senior Manager, ldaho Power Company.
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 26
REQUEST FOR PRODUCTION NO. 20: PIease explain why the Unit No. 1,
(1D) pulverizer exceeded 20,000 hours of operation prior to identiffing the significant
wear and parts that had deteriorated beyond the service life expectations. (BARRETTO,
Dr 13).
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Please see the
Response to Request for Production No. 19 for a discussion on why Unit 1 exceeded
expected hours of operation. The partners ceased budgeting for routine overhauls of
pulverizers because the plant was approaching its anticipated end-of-life. Operating
assumptions at that time were that units would have summer operation only and the
plant would be able to repair any actual failures of equipment during the remainder of
the year.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 27
Did the downtime on the Unit No. 1,
(1D) pulverizer, cause any downtime or reduced output on Valmy Unit No. 1? lf 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.
Unit 1 was derated to
240 net megawatts ('MW') from September 20,2019 to September 29,2019, and then
back to rated full load on September 30, 2019. The plant was able to generate the
requested load between September 29, 2019, and November 4, 2019. On November 5,
2019, the appropriate repairs were completed as the unit entered an economic (reserve)
shutdown, or a period in which it was not cost effective for the unit to run. ldaho Power
cannot precisely estimate the additional costs associated with the Company's share of
the reduction, 7 MW, during the ten-day derate window.
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 REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.2S
REQUEST FOR PRODUCTION NO.22: Please provide details and analysis
explaining the Unit No. 1 circulating water pump failure due to the ground fault.
(BARRETTO, Dl 15).
: Please see
Attachments 24 and 25 of the Response to Request for Production No. 12for the AFE's
in support of the replacement of the Unit 1 circulating water pump, including the cost
benefit analysis. Attachment 1 to this request provides the detail and analysis of the
failed Unit 1 circulating water pump.
The response to this Request is sponsored by John Carstensen, Joint Project
Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 29
REQUEST FOR PRODUCTION NO. 23: Please provide details and analysis
explaining the Unit No. 1 (1A) primary air fan motor damage. (BARRETTO, Dl 16).
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: Please see
Attachment 32 to the Response to Request for Production No. 12for the AFE in support
of the replacement of the Unit 1 primary fan motor, including the cost benefit analysis.
Attachment 1 to this response provides the details and analysis of the Unit 1 primary air
fan motor damage.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 30
REQUEST FOR PRODUCTION NO. 24: ln BARRETTO, Dl, Exhibit No. 2, Page
1 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 SCRUBBER ATOMIZER WHEELS, R.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: A dry scrubber utilizes
nine atomizing spray machines, each with their own atomizer wheel for a total of nine
wheels on the Unit 2 dry scrubber, to atomize Iime/recycled fly ash mixed slurry that
reacts with the sulfur dioxide fSO2") in the flue gas to produce calcium sulfate. The
solid calcium sulfate particles are then collected along with the fly ash in the baghouse.
To accomplish this, the scrubber atomizer wheels rotate at approximately 13,000
revolutions per minute and the centrifugalforce shears the lime/recycled ash slurry into
very small droplets for intimate liquid/gas contact. The scrubber atomizer wheels are
exposed to a harsh environment of fly ash laden flue gas as wel! as a spray of an
abrasive slurry of lime and ash through the force of the shearing. This causes erosion
on both the carbide slurry nozzles and the titanium wheel body, requiring routine
replacement.
An atomizer wheel can be expected to last for 10,000 - 12,000 hours in service.
With the plant's increased load in 2018,2019, and 2020 the existing atomizer wheels
were at the end of their service life, and no longer capable of being rebuilUbalanced.
The three projects for the procurement of new atomizer wheels were necessary to
ensure the plant's reliability for the 2019, 2020 and 2021 summer peak seasons and for
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCT]ON REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 31
environmental compliance for both the Title V SO2 removal and sulfur emissions as well
as the Mercury and Air Toxics Standards SO2 emissions.
The response to this Request is sponsored by John Carstensen, Joint Projec$
Leader, ldaho Power Company.
IDAHO POVVER COMPATIY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF TTIE
COMMTSSION STAFF TO TDAHO POWER COIvIPAT.IY - 32
REQUEST FOR PRODUCTION 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, Dl Exhibit No. 2, page2 oi
3).
RESPONSE TO REQUEST FOR PRODUCTION NO. 25: The plant did not
perform a root cause analysis for the failed conveyor belt as it is not NV Energy's
standard practice to perform root cause analyses when conveyor belts fail.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POI/\'ER COMPANY'S RESPONSE TO THE SECOND PRODUCT]ON REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 33
REQUEST FOR PRODUCTION NO. 26: Please provide evidence that the
replacement of the gearbox related to project 27570622 - VALMY 98481652 VC 58
COAL UNLOAD CONVEYER BELT, REPLACE VA. was implemented in a cost-
effective manner (BARRETTO, Dl Exhibit No. 2, page 2 of 3).
RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Please see
Attachment 20 to the Company's Response to Request for Production No. 12 for the
AFE supporting the replacement of the 58 conveyor belt and gearbox, including the cost
benefit analysis. ConfidentialAttachment 1 to this request, the Request for Proposals,
showed very long lead times for a replacement gearbox, so the decision was made to
rebuild the gearbox with support from Ryan Mechanical, the maintenance Long Term
Service Agreement contractor.
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 REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 34
REQUEST FOR PRODUCTION NO. 27: ln reference to project 27534969 -
VALMY 98455853 V2 PULVERIZER MOTOR 2D, REBUILD, are 600 HP pulverizer
motors common and interchangeable between Unit Nos. 1 and 2?
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: No. The pulverizers
on Unit 1 are manufactured by Babcock and Wilcox and the pulverizers on Unit 2 are
manufactured by Foster Wheeler. The motors are not interchangeable.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.3s
REQUEST FOR PRODUCTION NO. 28: For project "27574743 - VALMY
98482392 V2 REPLACE TURBINE HP/IP SECTION" identified in Exhibit No.2 of
Barrefto, Dl, please explain how the project was completed at least cost. ln 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. 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 . NVE indirect and/or direct charges made to the project.
g. Company indirect and/or direct charges made to the project.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 36
RESPONSE TO REQUEST FOR PRODUCTION NO. 28:
a. The NVE assigned project code is VF2235 and the ldaho Power work order
number is27574743.
b. Please see Attachment 1 to the Response to Request for Production No. 12
for the AFE that supports the replacement of the Unit 2 turbine high
pressure/intermediate pressure shells. ln addition, Attachment 1 to this
response includes the Key Decision Report prepared by the plant.
c. The turbine OEM was selected based on access to original drawings and
expertise in repairs.
d. Please see Attachment 2 for the project scope of work and Attachment 3 for
the schedule, status report, and action items dated February 17,2021.
Because of the short duration of this project, no monthly updates were
prepared. The most significant change of project scope was due to the
discovery of additiona! damage and required the repair of the turbine inner
shell mating surfaces and replacement of three inner shell tapped studs.
e. Please see d.
f. The following summarizes ldaho Power's share of NVE's direct and indirect
charges made to the project:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 37
Budoeted OH Rate $58.081.54
Non-!nventorv Goods s41.571.il
OH Rate Variance $810.97
Other Pav $3.408.69
Other Vouchers $1.585.60
Outside Services Emploved $808,695.45
Overhead - Admin & General $20.435.48
Overhead - Materials $30.985.41
Overhead - Proiect Supervision $19,051.02
Overhead - Purchasino I )415.73
Overtime $81.841.95
Reqular Pav $66.516.12
Stock Material Returns -$7.979.32
Stock Materials $110.662.14
Travel Meals and Lodqinq $3.041.38
Valmv i1.239.123.80
g. The project included additional ldaho Power charges of $1,841.04 in
overheads, for a total project cost of $1,240,964.84.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 38
REQUEST FOR PRODUCTION NO. 29: For project "27514784 - VALMY
98438396 VC FREEZE PROTECTION HEATERS," identified in Exhibit No. 2 of
Barretto, Dl Testimony, how the project was completed at least cost. ln 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
iii. Organizational chart
iv. Schedule (baseline versus actual)
v. Monthly project status reports
vi. Action items list(s)
vii. Contractor change order requests
t. Project correspondence discussing:
viii. Project change in scope
ix. Project delay
x. Project cost overruns
g. NVE indirect and/or direct charges made to the project
IDAHO POIA'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMTSSION STAFF TO IDAHO POWER COMPANY - 39
h. Company indirect and/or direct charges made to the project.
RESPONSE TO REQUEST FOR PRODUGTION NO. 29:
a. The NVE assigned project code is VA2140 and the ldaho Power work order
number is 27514784.
b. Please see Attachments 2 and 3 to the Response to Request for Production
No. 12 for the AFE's that support the installation of the freeze protection
heaters. The cost benefit analysis begins on page 9 of each AFE.
c. Please see Attachments 1 through 3 for the Request for Proposals issued for
the freeze protection heaters and supporting exhibits. Attachment 4 includes
the Technical Submittal Requirements and ConfidentialAttachment 5
includes the Bidders List.
d. Please see ConfidentialAttachments 6 through 8 and Attachment 9.
e. Not applicable. All construction/installation was performed in house.
f. See e above.
g. The following summarizes ldaho Power's share of NVE's direct and indirect
charges made to the project:
Budqeted OH Rate $2.967.43
Non-lnventorv Goods $442.778.00
OH Rate Variance $63.52
Other Vouchers $1.851 .37
Outside Services Emoloved s34.742.97
Overhead - Admin & Genera!$11,398.27
Overhead - Materials $1.256.61
Overhead - Proiect Supervision $20.546.88
Overhead - Purchasinq $4.555.70
Reqular Pav $3.965.86
Stock Material Returns $(29.62)
Stock Materials $5,342.00
Valmv $529.438.99
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY -40
h. The project included additional ldaho Power charges including a ($0.35)
miscellaneous corection, $10,827.31 of Allowance for Funds Used During
Construcfion (?FUDC') and $1,058.86 in overheads, for a totalproject cost of
$541,324.81.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POVVER OOMPANY's RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
coMMtsstoN STAFF TO TDAHO pOVvER COMpAtIy - 41
REQUEST FOR PRODUCTION NO. 30: Please provide the work order jackets
and source documents for the following projects:
Proiect Description Total
27574743
VALMY 98482392 V2 REPLACE TURBINE HP/IP
SECT!ON $ '1.240.965
27514784
VALMY 98438396 VC FREEZE PROTECTION
HEATERS $ s41.325
27555279
VALMY 98455852 VC GROUND WATER
MONITORING WEL $ 219.799
27545751
VALMY 98466935 V1 PULVERIZER D ROLL
WHEEL ASS $ 159.459
27539554
VALMY 98467485 V2 SCRUBBER OUTLET DUCT
PLUGGA $ 126,7s9
27539687
VALMY 98462057 V2 STACK ELEVATOR,
REPLACE $ 107.341
27570622
VALMY 98481652 VC 58 COAL UNLOAD
CONVEYER BELT. REPLACE VA $ 885.8s3
275s1304
VALMY 98453212 V2 SKY CLIMBER
ATTACHMENT PLATFORM, INSTALL $31.051
27533143
VALMY 98459393 V1 1ST POINT FEEDWATER
!NLET VALVE. REFUR $14.564
27502697
VALMY 98434354 V1 LOW NOX BURNER
NOZZLES, REP $13.148
RESPONSE TO REQUEST FOR PRODUCTION NO. 30: Attachments I
through 10 include the work order jackets and supporting documents for the above-
mentioned work orders.
The response to this Request is sponsored by Anne Wadsworth, Joint Venture
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMM]SSION STAFF TO IDAHO POWER COMPANY - 42
REQUEST FOR PRODUCTION NO.31: PIease provide any SOX Compliance
Reports and internal audit reports with supporting workpapers for the Valmy facility. ln
addition, please provide the Valmy Billing Review Audit reports and workpapers for the
years 2018, 2019, 2020, and 2021 .
RESPONSE TO REQUEST FOR PRODUCTION NO. 31: Audit Services
performed audits of internal controls related to the Valmy facility during the period of
2018 to 2021 as part of complying with Sarbanes-Oxley ('SOX') requirements. The
related SOX processes are Joint Ventures Fuel Receipts and Consumption ("JVFR')
and Joint Ventures Vouchers & Disbursements ('JWD'). Controls within these
processes apply to the Valmy, Bridger, and Boardman facilities. Therefore, some
information provided will include additional information not specific to the Valmy facility.
Audit Reports are only issued for SOX internal control audits in the event of a finding(s).
SOX testing is performed on a rotational basis. The following table provides testing
performed on these SOX processes by year:
Audit Services may perform operationalaudits related to the Valmy Operating
Agreement in accordance with its annual audit plan. During the period of 2018 to 2021
an operational audit was performed over 2018 charges to ldaho Power. An audit over
2020 charges is in process but not complete. Due to the voluminous nature of the
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 43
SOX Prccess/Control
c04
2018 2019
x
2020 2021ffi
x
x tc05
EWC C02
c04 x
x
x
x
c08 x x
EWC C02 Noucher 78)x x
El/VlC C02 (Voucherc 49. 50. and 51)x x
supporting documentation for all audits described, it has not been provided in this
response. However, the material is availabb for review at the Company's headquarters.
Please contact Tami\A/hite at [phone] or Dave Fewkes at [phone] to
schedule a time to review the requested information. Confidentia! Attachment Nos. 1
through 13 include the audits of internal controls and ConfidentialAttachment No. 14
includes the Valmy Operating Agreement audit results.
The response to this Request is sponsored by Sonse Sutezzo, Operations Audit
Manager, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 44
DATED at Boise, ldaho, this 12th day of April2022.
frL!.fl"*t.-*,
LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POVI'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVI'ER COMPA].IY . 45
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of April2022, ! served a true and correct
copy of ldaho Power Company's Response to Second Production Request of the
Commission Staff to ldaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Taylor Brooks
Deputy Aftorney Genera!
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No.8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
_Hand Delivered_U.S. Mail
Overnight Mai!_FAXX FTP SiteX Email: [e-mail]
&r.J.
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 46