20230908IPC to Staff 237-241.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

September 8, 2023

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-23-11
Idaho Power Company’s General Rate Case

Dear Ms. Noriyuki:

Enclosed for electronic filing, please find Idaho Power Company’s Response to
Request Numbers 237, 238 b., 239, 240, and 241 a.-d to the Eleventh Production Request
of the Commission Staff to Idaho Power Company. Because of the volume of
documentation requested in the Eleventh Production Request, the Commission Staff
agreed it would be acceptable the Company provided the responses in a minimum of two
tranches. The Company provided the first segment of responses and supporting
documentation on August 30, 2023. This filing represents the second and final segment
of responses and supporting documentation to the remainder requests.

Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the attachment
to these requests to the secure FTP site to allow parties to view the requested information
remotely unless otherwise noted in the response. Because certain attachments contain
confidential information, the FTP site is divided between confidential and non-confidential
information.

The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site has been provided the parties that have executed the
Protective Agreement in this matter.

RECEIVED
2023 SEPTEMBER 8, 2023 4:56PM
IDAHO PUBLIC
UTILITIES COMMISSION
Jan Noriyuki
September 8, 2023
Page 2

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,

Megan Goicoechea Allen
MGA:sg
Enclosure

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-23-11
In the Matter of the Application of Idaho Power Company for Authority to Increase
Its Rates and Charges for Electric Service to Its Customers In the State of Idaho
and For Associated Regulatory Accounting Treatment

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that Attachment 5 provided in Response to Request No. 239 and Attachment 3
provided in Response to Request No. 241, as included in Idaho Power Company’s
Response to the Eleventh Production Request of the Commission Staff dated September
8, 2023, contain information that Idaho Power Company and a third party claim are trade
secrets, and/or business records of a private enterprise required by law to be submitted
to or inspected by a public agency, as described in Idaho Code § 74-101, et seq., and/or
§ 48-801, et seq. As such, they are protected from public disclosure and exempt from
public inspection, examination, or copying.

DATED this 8th day of September, 2023.

Megan Goicoechea Allen
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-11

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Eleventh Production Request of the Commission Staff (“Commission” or
“Staff”) dated August 16, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 237: Please provide the following
documentation for the Valmy Ground Water Monitoring Well Installation (Project No.
27555279) referenced in Barretto Direct Testimony at 31. If any of the information
requested below cannot be provided or is not available, please explain why, and also
explain how the Company can ensure the construction of the project was completed in a
least-cost manner.
a. A copy of the Nevada Division of Environmental Protection ("NDEP")'s well
monitoring guidelines.
b. Copies of reports or documentation demonstrating 9 wells that were reading critical
ground water levels (five wells that were reading above top screen level and four
wells that were close to be invalid).
c. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
d. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
e. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
f. Project construction documentation including:

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
g. Company project completion analysis
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
h. Documentation specific to Idaho Power approving the project prior to start of
construction.
i. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost manner to its customers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 237:
a. Groundwater monitoring is a requirement at Valmy by three regulatory requirements:
Nevada Division of Environmental Protection (“NDEP”) Authority to Discharge Permit
No. NEV96015, NDEP Landfill Permit No. SW174R03, and Federal Environmental

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
Protection Agency (“EPA”) Coal Combustion Residuals (“CCR”) regulations at 40
CFR 257.90, which can be found here:
 NDEP Authority to Discharge Permit: Nevada Revised Statutes 445A.475:
NRS: CHAPTER 445A - WATER CONTROLS (state.nv.us)
 NDEP Landfill Permit – See Attachment 1 – Response to Staff Request No.
237 for a copy of the NDEP landfill permit. Section 7 of the permit details the
groundwater monitoring guidelines.
 CCR regulation 40 CFR 257.90: eCFR :: 40 CFR 257.90 -- Applicability.
b. Prior to late 2019, the major factor driving site hydrogeological conditions at the
Valmy site was dewatering activities and the cessation of dewatering operations at the
Lone Tree Mine. The open-pit mine is five miles southwest of Valmy and on the opposite
side of the Humboldt River. Mine dewatering from 1994 to 2007 coincided with a
decrease in groundwater elevation across the region of approximately 75 feet at Valmy,
to an approximate elevation of 4,325 feet. Groundwater elevations across the region
began to recover when dewatering from the mine ceased in 2009. This resulted in
groundwater rebound of approximately 75 feet at Valmy through mid-2019, or up to an
elevation of 4,399 to 4,400 feet. The increase in groundwater elevation rapidly changed
the type and thickness of geologic materials saturated in the uppermost aquifer. Once
the groundwater elevations showed signs of stabilization, new groundwater monitoring
wells were installed.
Attachment 2 – Response to Staff Request No. 237 includes the latest professional
engineer certification for the groundwater monitoring system at Valmy, as required by
§257.91(f) of the EPA’s CCR Rule and was written to demonstrate compliance with

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
§257.91. Figures 2 through 4 depict a cross-section of the groundwater monitoring
system. The well screens are identified as vertical black lines. As can be seen by the
horizontal dashed lines, beginning in 2016, the water levels had risen above well
screens, fully submerging the screened interval intake. By 2019, the majority of the well
screens were submerged. The Valmy Ground Water Monitoring Well Installation project
drilled shallower wells, and with monitoring well screens set at shallower depths to
account for the effect of groundwater rise on the uppermost aquifer. The new well
screens are depicted as the vertical black lines slightly offset from the original deeper
wells.
c – i. The response to this Request was provided on August 30, 2023.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
STAFF REQUEST FOR PRODUCTION NO. 238: According to Company Witness
Barretto's Direct Testimony at 20, the Company found it is more cost-effective to purchase
Freeze Protection Heaters than renting Portable Electric Space Heaters for the Valmy
Plant with an approximate cost of $541,000. Please provide the following information as
requested. If any of the information requested below cannot be provided or is not
available, please explain why, and also explain how the Company can ensure the
construction of the project was completed at least cost.
a. A justification of need for the project and a cost-benefit analysis.
b. Details on previous rental contract or orders of Portable Electric Space Heaters since
2012 until the purchase and installation of the Freeze Protection Heaters.
c. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
d. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
e. Documentation specific to Idaho Power approving the project prior to start of
construction.
f. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost manner to its customers.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 238:
a. The response to this Request was provided on August 30, 2023.
b. Due to the age of the requested documents, and the change of systems that contain
electronic copies of invoices, the plant was unable to locate invoices or purchase
orders associated with the rental of the electric space heaters. However, as can be
seen in the cost benefit analysis provided as Attachments 31 and 32 – Response to
Staff Request No. 169, the estimated cost of the electric heater rental utilized in the
analysis was $282,874 per year. Further, as shown in Attachment – Response to
Staff Request No. 238, the purchase order history pulled from Valmy’s accounting
records, confirms a total cost of the heaters from Sunbelt Rentals for the September
2017 through 2018 time period of $354,410.
c – f. The response to this Request was provided on August 30, 2023.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
STAFF REQUEST FOR PRODUCTION NO. 239: Please provide the following
information as requested on the Project No. 27493693 (Bridger 2017C110 U4 Boiler
Optimization System 17). If any of the information requested below cannot be provided
or is not available, please explain why, and also explain how the Company can ensure
the construction of the project was completed at least cost.
a. The following details on the neural network combustion controls and soot blowing
optimizer (including but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
b. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
c. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
d. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
e. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
f. Company project completion analysis:
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
g. Documentation specific to Idaho Power approving the project prior to start of
construction.
h. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost manner to its customers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 239:
a. The neural network combustion controls and soot blowing optimizer are simply
software packages that consist of computer models that require personnel to tune
the models. The first NeuCo system at Bridger was purchased around 2006 for Unit
2. See Attachment 1 – Response to Staff Request No. 239 for a presentation made
by NeuCo at the time detailing their ProcessLink Solutions and their specifications for

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
Unit 2. The same system was installed on Unit 4.
b -c. See Attachment 2 – Response to Staff’s Request No. 239 for the Project Proposal
and Attachment 3 – Response to Staff’s Request No. 239 for the cost benefit analysis,
which detail the project need and project plan.
d. No RFP was issued. The OEM GE/NeuCo was selected based on proven value from
the previously purchased systems on Unit 2 and because it would provide for a single
Neural Network Optimization platform. See Attachment 4 – Response to Staff
Request No. 239 for the Non-Compete Justification and Confidential Attachment 5 –
Response to Staff Request No. 239 for the GE Power Digital proposal for Bridger’s
boiler optimizer software solution.
e. There are no construction documents associated with this project because it is an
installed software solution.
f. Idaho Power’s original budgeted work order approval amount was $268,179. The
Company’s share of actual project costs were $217,915, resulting in a variance of
negative $50,264, or more than 18 percent under budget.
g. Idaho Power’s approval of the Bridger capital projects occurs as part of the yearly
budget approval process. Following the Jim Bridger Ownership Meeting with the
budget presentation, the Company provides the plant written authorization of the
capital budget as well as a list of the capital projects that make up that budget amount.
Please see Attachments 6 and 7 – Response to Staff Request No. 239 for the
Company’s approval of those capital projects over $250,000 anticipated for the
calendar year 2017, when both the Unit 1 and Unit 4 boiler optimization system
upgrades were anticipated to begin. The Unit 4 boiler optimization system upgrade is

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
shown on line 27 of Attachment 7 – Response to Staff Request No. 239.
h. As explained in the Company’s Response to Request for Production No. 161, once
the budget is approved for Bridger, during each quarterly Ownership Meeting, a
standing agenda item is to review the current year capital and O&M expense budget,
routinely providing Idaho Power the opportunity to raise any questions necessary
about projects. Additionally, on a monthly basis, forecasts for capital and O&M
expense are provided for review by the Company. Idaho Power is continuously
involved in capital investment discussions, both prior to the project commencing and
during the completion phase, providing input and approval, and ensuring the projects
are being completed in a least cost manner.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
STAFF REQUEST FOR PRODUCTION NO. 240: Please provide the following
information as requested on the Project No. 27475574 (Bridger CITC2017C207 Backup
Bandwidth Upgrades 2017). If any of the information requested below cannot be provided
or is not available, please explain why, and also explain how the Company can ensure
the construction of the project was completed at least cost.
a. The following details on previous/deprecated radio communications at the plant
(including but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
b. The following details on the upgraded radio communications at the plant (including
but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
c. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
d. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
e. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
iv. RFP from winning bid.
f. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
g. Company project completion analysis:
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
h. Documentation specific to Idaho Power approving the project prior to start of
construction.
i. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost manner to its customers.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 240:
a-d. The backup bandwidth upgrades project was a corporate information technology
project implemented by PacifiCorp beginning in 2017 for several of their thermal
generation plants, including Bridger. The primary leased circuits that were serving
PacifiCorp’s thermal plants were backed up by reduced-bandwidth circuits over
private facilities. Those existing secondary circuits had become inadequate to
maintain high priority data traffic, such as VoIP phones, during outages of the primary
leased circuits. The upgrades to PacifiCorp’s private network provided an opportunity
to increase the backup circuits at Bridger to a bandwidth capable of meeting the
increased requirements of the thermal plants. The existing circuits were replaced with
new circuits and the rest were in-place upgrades. The upgrades did not result in any
equipment being removed from service but rather maintenance for the existing
circuits would no longer be necessary. Without the upgrades, outages on the leased
circuits would have resulted in failure of basic data services. See Attachment –
Response to Staff’s Request No. 240 for the project purpose and necessity form
completed for the project with the costs specific to Bridger detailed on the tab titled
Site Info.
e - f. There was no RFP issued specific to the Bridger back-up bandwidth upgrade as
the work was performed by internal telecommunications and network engineer
personnel and therefore there is no project construction documentation.
g. The back-up bandwidth upgrade project was an unbudgeted project that was added
to the Bridger budget in December 2016, to begin in 2017 and continue through 2019.
However, as can be seen on the Appropriation Request Summary Report provided

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
with the APR submitted as Attachment 1 – Response to Staff’s Request No. 164, the
original estimate of projects costs specific to Bridger was $50,199. Note, while the
Company’s share of actual project costs presented in Exhibit No. 3 is $130,809, it
was determined approximately $99,000 of the charges were intended for a different
Bridger project completed at the same time and applied to this project in error.
PacifiCorp will correct for the error during the next billing month, applying costs to the
appropriate project. Therefore, total project costs were below budget.
h. See (g). Because the project was unbudgeted, the project was not a component of
the yearly budget approval process. In addition, because the project fell below the
threshold, written authorization by Idaho Power to the plant was not required.
i. As explained in the Company’s Response to Request for Production No. 161, once
the budget is approved for Bridger, during each quarterly Ownership Meeting, a
standing agenda item is to review the current year capital and O&M expense budget,
routinely providing Idaho Power the opportunity to raise any questions necessary
about projects. Additionally, on a monthly basis, forecasts for capital and O&M
expense are provided for review by the Company. Idaho Power is continuously
involved in capital investment discussions, both prior to the project commencing and
during the completion phase, providing input and approval, and ensuring the projects
are being completed in a least cost manner.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
STAFF REQUEST FOR PRODUCTION NO. 241: Please provide the following
information as requested on the Project No. 27574748 (Valmy 98483985 V2 Ovation HMI
and Server Update). If any of the information requested below cannot be provided or is
not available, please explain why, and also explain how the Company can ensure the
construction of the project was completed at least cost.
a. The following details on previous/deprecated Emerson Ovation Distributed Control
System ("DCS") equipment at the plant (including but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
b. All communications with Emerson confirming the end of previous DCS's original
equipment manufacturer ("OEM") support.
c. The following details on upgraded DCS at the plant (including but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
d. A copy of the latest Top 20 Critical Security Controls ("CSC") SANS guidelines for
cyber defense and detection tools, as mentioned in Exhibit No. 2 Barretto Direct at
1.
e. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
f. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
g. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
h. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule.
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
i. Company project completion analysis:
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
j. Documentation specific to Idaho Power approving the project prior to start of
construction.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
k. Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 241:
a. The Unit 2 Emerson Ovation Distributed Control System (“DCS”), which was
installed in 2015, was operating both the servers and Human Machine Interface
(“HMI”) beyond the Original Equipment Manufacturer (“OEM”) support and security
patches were no longer being created. The control servers were operating on
Windows Server 2008 and Microsoft ceased mainstream supporting as of January
1, 2020. The HMIs are operating on Windows 7 originally released in 2009 with a
service pack update in 2016, which Microsoft stopped supporting as of January 14,
2020. The Emerson systems were not the only cyber security risk at the plant and
following an evaluation of how to minimize risk, and minimize cost, it was determined
to update those systems that were network connected and leave the other systems
as-is.
Further, although there is no specific standard, full control system upgrade life-
cycle is about 10 years, with a 5-year mid-cycle HMI and operating system update.
These timelines are guidelines and can vary slightly to align with plant outage cycles
and cybersecurity risk concerns. Additionally, the operating system version update
cycle and vendor application refresh cycle variabilities can sometimes cause shorter
or longer cycles than the typical 5 and 10 year time span. Given Unit 2’s existing
control system was commissioned in 2015, it had reached the mid-cycle HMI and
operating system upgrade requirement. The project was planned to align with other
cybersecurity project upgrades, the anticipated operating schedule and to maximize

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
the project benefits given the unit retirement date. An additional concern existed with
the scheduled 2021 retirement of Unit 1. A number of common plant systems were
controlled from Unit 1’s DCS and require code changes to move the controls to Unit
2’s DCS.
b. See part (a). There were no specific communications with Emerson regarding the
end of the OEM support for the previous DCS as the support referenced was with
respect to the Microsoft Windows Server 2008 and Windows 7 programs which were
no longer supported.
c. The upgrade replaced the HMI hardware and upgraded the operating system to
Windows 10. The following control equipment was also upgraded: Virtualized
Windows 2019 control servers host, Emerson Ovation software upgrade from level
3.5.1 to 3.8, and new Ethernet switches and routers. Additionally, cyber security
policies required the Programmable Logic Controllers (“PLC”) replacement or
upgrades to maintain compliance. The Unit 2 Scrubber PLC was migrated into the
Ovation Control System. In addition, the Generator Exciter EX2000 PLC required
replacement and point mapping into the Ovation controls.
d. Please see Attachments 1 and 2 – Response to Staff Request No. 241 for
information regarding the Top 20 CSC SANS guidelines for cyber defense and
detection tools in place at the time the Ovation HMI and server update were
performed.
e – k. The response to this Request was provided on August 30, 2023. See also
Confidential Attachment 3 – Response to Staff Request No. 241 for additional
documentation gathered by NV Energy in support of the Ovation HMI and Server

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
Update of Unit 2.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
DATED at Boise, Idaho, this 8th day of September 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 22
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 8th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Eleventh 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
Chris Burdin
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
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Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]

Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
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U.S. Mail
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FAX
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X Email [e-mail]

Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703

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[e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 23
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 24
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585
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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
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Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
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Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
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Stacy Gust, Regulatory Administrative
Assistant