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Home My WebLink About20220513IPC to Staff 3rd Production Response No. 9 - Redacted.pdf JULIA A. HILTON Deputy General Counsel and Director of Legal jhilton@idahopower.com May 13, 2022 Jan Noriyuki, Secretary Idaho Public Utilities Commission 11331 W. Chinden Boulevard Building 8, Suite 201-A Boise, Idaho 83714 Re: Case No. IPC-E-22-11 Application of Idaho Power Company for Authority to Implement Power Cost Adjustment (“PCA”) Rates for Electric Service from June 1, 2022, through May 31, 2023 Dear Ms. Noriyuki: Attached for electronic filing is Idaho Power Company’s Response to the Third Production Request of the Commission Staff in the above-entitled matter. The confidential attachments will be provided in a separate encrypted email to the parties who sign the protective agreement. If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, Julia A. Hilton JAH:sg Enclosures RECEIVED 2022 May 13, PM 2:45 IDAHO PUBLIC UTILITIES COMMISSION IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF - 1 LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6935 lnordstrom@idahopower.com Attorney for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO IMPLEMENT POWER COST ADJUSTMENT (“PCA”) RATES FOR ELECTRIC SERVICE FROM JUNE 1, 2022, THROUGH MAY 31, 2023. ) ) ) ) ) ) ) ) CASE NO. IPC-E-22-11 IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the Third Production Request of the Commission Staff dated May 10, 2022, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF - 2 REQUEST FOR PRODUCTION NO. 9: Regarding Production Request (PR) No. 6, please respond to the following for Hells Canyon #3 relative to the forced downtime that started on 4/1/2021 through 4/1/2022 (according to the response). (a) Please provide a detailed explanation for the cause of the downtime including the root cause(s). (b) Is unit #3 still offline? If so, when is it expected to come back on-line? (c) Why has it been down for over a year? What has the Company done to rectify the situation to bring the unit back online? If the unit is not currently online, what is the Company currently doing to rectify the situation and bring the unit back online? (d) Was it possible to bring the unit on-line sooner? If so, please explain how and describe the associated cost compared to the Company’s chosen timeline. (e) According to the response to PR No. 6, 1,143,180 Megawatt-hours during the 2021-2022 PCA deferral period of zero-fuel cost generation were lost. Please calculate the additional cost of replacing the generation from that unit due to the outage. (f) Please provide any documentation showing the Company’s analysis of the downtime that address the questions above. RESPONSE TO REQUEST FOR PRODUCTION NO. 9: a) Unit 3 failed due to a phase-to-phase fault in the stator on June 23, 2020. The likely root cause was degraded coil insulation. At the time of failure, Idaho Power had already planned for scheduled maintenance from August 2021 to December 2021 (with a targeted back in service date of February 2022) and was under contract with Alstom Renewable US (General Electric). As a result of the failure, however, IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF - 3 Idaho Power negotiated a change order to accelerate the previously scheduled rewind project to begin June 1, 2021, establishing an in-service date of August 2021. b) The unit was back on-line on May 11, 2022. c) As discussed in part (a) to this response, Unit 3 failed due to a phase-to-phase fault in the stator. Once the unit was disassembled, additional, unanticipated work was discovered requiring unexpected manufacturing of additional parts and lead time for materials. This moved the rewind date to June 1, 2021 to December 18, 2021. The resulting project completion moved to February 2022. d) While there were some performance and workmanship issues as well as delayed completion of the contracted work by General Electric, Idaho Power crews consistently worked twelve-hour days, six to seven days a week, to reassemble and commission the unit once General Electric left the site in late April 2022. e) The 1,143,180 megawatt-hours provided in response to Staff’s Production Request No. 6 represent nameplate capacity multiplied by total hours of downtime. It does not represent the net impact of the outage to customers, which would require additional analysis to determine the overall impact of the unit’s lack of availability on the Company’s operations over that time period. However, as IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF - 4 discussed in part (d) to this response, f) Please see confidential attachments 1 – 5 to this response. Please note that the three change orders provided contain support for the timelines and values discussed in parts a, c, and d of this response. Change orders not specific to this response have not been provided. The response to this Request is sponsored by Ryan Adelman, Vice President of Power Supply, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF - 5 DATED at Boise, Idaho, this 13th day of May 2022. ____________________for_________ LISA D. NORDSTROM Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 13th day of May 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 Dayn Hardie 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 Hand Delivered U.S. Mail Overnight Mail FAX _____ FTP Site X Email: Dayn.Hardie@puc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson 515 N. 27th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX _____ FTP Site X Email: peter@richardsonadams.com Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 Hand Delivered U.S. Mail Overnight Mail FAX _____ FTP Site X Email: dreading@mindspring.com ________________________________ Stacy Gust, Regulatory Administrative Assistant BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-11 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 9 ATTACHMENT NO. 1 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-11 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 9 ATTACHMENT NO. 2 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-11 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 9 ATTACHMENT NO. 3 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-11 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 9 ATTACHMENT NO. 4 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-11 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 9 ATTACHMENT NO. 5