20220615IPC to Staff 32.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
June 15, 2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-22-05
In 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, please find Idaho Power Company’s Response to the
Third Production Request of the Commission Staff in the above matter.
If you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosure
RECEIVED
2022 JUN 15 PM 2:36
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
DETERMINATION VALIDATING THE
NORTH VALMY POWER PLANT
BALANCING ACCOUNT TRUE-UP.

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CASE NO. IPC-E-22-05

IDAHO POWER COMPANY’S
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Third Production Request of the Commission Staff (“Staff”) dated June
8, 2022, herewith submits the following information:
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IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 32: Please address the following questions
related to the pdf file “BTU and THERMS TONNAGE ADJUSTMENT 21-06” attached to
the email response made by Curtis Bradfute of NV Energy on July 30, 2021, as a
request for clarification to the heat rate attributed to Idaho Power’s portion of the North
Valmy Plant by Randall Henderson. The attachment by Mr. Bradfute is provided within
the email message file “_EXTERNAL_Final BTU and Therms Sheet for Valmy 06-21
(Question from Monthly Meeting)” submitted in response to Production Request
Response No. 9:
a. Please explain why Unit No. 1 shows both coal usage and generation for
Idaho Power past the December 2019 exit date.
b. Please explain why the coal usage and generation values for Unit #1
provided in the workpapers are not shown correctly on the summary
sheet.
c. If the Company did take generation from Unit No. 1 and given that the
Company is paying early exit fees on Unit No. 1, please explain how the
transaction does not harm the Company’s customers.
d. The email message states, “The values from usage report are reading IPC
values from Unit 1 but they are added to Unit 2 in the worksheet. I have
reached out to our IT team to see why IPC has reading from Unit 1 on this
report but they are still researching this.” Please explain how this issue
has been resolved.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
RESPONSE TO REQUEST FOR PRODUCTION NO. 32
a. and b. During Idaho Power’s monthly review of the North Valmy Power
Plant’s (“Valmy”) coal burn and usage report provided by NV Energy for
the month of July 2021, titled BTU and Therms Tonnage Adjustment, the
Company noticed the heat rates reported for Unit 1 and Unit 2 were not
similar and BTUs associated with Unit 1 were being allocated to Idaho
Power. In addition, the heat rates were different than what had been
reported recently in the North American Electric Reliability Corporation’s
Generating Availability Data System for the units. This oddity was called to
the attention of NV Energy. After further investigation, it was determined
the NV Energy internally generated report that calculates BTU’s
consumed by unit, the Valmy Usage Report, had not been modified to
reflect Idaho Power’s exit of Unit 1 operations. BTU’s consumed by unit
reflected in the Valmy Usage Report is the source of the data presented in
the BTU and Therms Tonnage Adjustment report and therefore
erroneously assigned Unit 1 usage to Idaho Power.
To correct for the reporting error, calculation adjustments were
made to the report to ensure only Unit 2 generation and coal consumption
is allocated to Idaho Power. Updates were made to unit heat rates and
accounting adjustments were recorded in November 2021 to correct for
the errors reported in the Company’s coal burn beginning in January 2020.
Following these report modifications and adjustments, Idaho Power is now
correctly allocated only fuel burn specific to Unit 2.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
c. Since Idaho Power’s exit from participation in operations of Unit 1 on
December 31, 2019, the Company has not received more energy than its
percentage share of the output of Unit 2, or 133.5 MW.
d. See a. and b. above.
The response to this Request is sponsored by Randall Henderson, Principal Joint
Projects Coordinator, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
DATED at Boise, Idaho, this 15th day of June 2022.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 15th day of June 2022, I served a true and correct
copy of Idaho Power Company’s Response to the Third Production Request of the
Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Taylor Brooks
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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