20110126PAC to Monsanto 19 (1-9).pdf

~~;:OUNTAIN
Janua 24,2011
Randall C, Budge
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHATERED
P,O, Box 1391; 201 E, Center
Pocatello, Idaho 83204-1391
RE: ID PAC-E-10-07
Monsanto Set 19th Data Requests (1-9)
ZOli JAN 26 At', 9: 34
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Please find enclosed Rocky Mountain Power's responses to Monsanto Set 19th Data Requests
19.1-19,9, Provided on the enclosed CD are Attachments Monsanto 19,1, 19.2 and 19,5,
Provided on the enclosed Confdential CD are Confidential Attachments Monsanto 19,8 -(1-2),
The Confdential Attachments are Confidential and are provided subject to the protective order
in this docket,
If you have any questions, please feel free to call me at [phone],
Sincerely,
-J. i..,d tt/t.¡;lc~/~
J, Ted Weston
Manager, Regulation
Enclosure:
cc: Jean JewelllPUC (C)I 3 copies
Eric OlsenlIPA (C)
Ben Otto/ICL (C)
James R, SmithIonsanto (C)
Richard Anderson/onsanto (C)
George C, Carer, IIIMonsanto (C)
Denns Peseau/onsanto (C)
Gareth R, Kajander/Monsanto (C)
Maurice Brubaker/Monsanto (C)
Brian Collns/Monsanto (C)
Michael Gormanonsanto (C)
Kath Iverson/Monsanto (C)
Mark Widmer/Monsanto (C)
Melinda Davison/IIC (C)
Eric LaceylNucor Steel
P AC-E-1 0-07/Rocky Mountain Power
Januar 24, 2011
Monsanto Data Request 19,1
Monsanto Data Request 19.1
Please provide all workpapers for the Januar 2011 rebuttal testimonies ofMr,
Duvall, Mr, Clements, and Mr, McDougal, including all workpapers and models
in electronic format with all formulas intact.
Response to Monsanto Data Request 19.1
Regarding the rebutt testimonies of Mr, McDougal and Mr, Duvall, no new
work papers or models were prepared, For workpapers related to Mr, Clements
testimony, please refer to Attchment Monsanto 19,1 -1 and Confidential
Attchment Monsanto 19,1 -2, Confidential information is provided subject to
the terms and conditions of the protective agreement in this proceeding,
Sponsor:
Gregory N, Duvall I Paul H, Clements
I Steven R, McDougal
Gregory N, Duvall I Paul H. Clements
I Steven R. McDougal
Recordholder:
PAC-E-10-07/Rocky Mountain Power
Januar 24,2011
Monsanto Data Request 19.2
Monsanto Data Request 19.2
With respect to Mr. Clements' Januar 2011 rebutt testimony at page 6, lines
10-19, please provide the following information:
a, The IRP analysis performed by the Company, including all workpapers and
models in electronic format with all formulas intact,
b, A description of the methodology used by the Company in performing the
analysis,
c, The results of the IRP analysis in electronic format with all formulas intact.
Response to Monsanto Data Request 19.2
a, Please refer to Attchment Monsanto 19.2 for the results of the analysis,
There are no workpapers other than the modeling results themselves, The
model used for the analysis, System Optimizer, is proprieta software
licensed to the Company by Ventyx Energy, LLC, and is not available to
distribute to third paries,
b, PacifiCorp ran its System Optimizer capacity expansion model with and
without the Monsanto contract included, The model set-up is the same one
being used to develop resource portfolios for its 2011 IRP, The analysis is
simply to compare the model's expansion plans with and without the
Monsanto resource included, and determine what resources were deferred or
elimated from the portfolio, The full complement of resource types-gas
plants, renewables, demand-side management products, and market
purchases-was made available to the model consistent with Company IRP
practice and state IR guidelines, For this study, PacifiCorp found that
removal of the Monsanto contract resulted primarly in additional reliance on
firm market purchases (front office transactions) and demand-side
management products,
c, Please refer to Attachment Monsanto 19.2 for the results of the analysis. The
System Optimizer's capacity expansion plans are shown along with a resource
capacity difference table showig what resources were deferred or eliminated
as a result of excluding the Monsanto contract from the resource portfolio,
Recordholder:
Sponsor:
Gregory N, Duvall
Gregory N, Duvall
PAC-E-IO-07/Rocky Mountain Power
Januar 24, 2011
Monsanto Data Request 19,3
Monsanto Data Request 19.3
With respect to the table at the bottom of page 8 and on page 9 in Mr, Clements'
Janua 2011 rebutt testimony, please provide the following information:
a, Identify all units that are operating strictly as simple cycle combustion
tubines (i.e" exclude combustion tubines that are par of a combined cycle
facility).
b. Indicate whether the simple cycle combustion turbines in part a, have
Automatic Generation Control (AGC) equipment installed,
c, For each simple cycle combustion tubine in par a" indicate whether that
simple cycle combustion tubine resides in a load pocket on the PacifCorp
system (where a load pocket is an area on the PacifiCorp system that,
because of transmission limitations, must have internal generation resources
available because the area canotbe served entirely by external resources),
d, Indicate, by year, for each simple cycle combustion turbine in par a,
whether any of the operational hours included in the table were for serving
load inside load pockets and not for the purose of providing ancilary
services,
e, Indicate, by year, for each simple cycle combustion turbine in part a, how
many of the operational hours included in the table were for serving load
inside load pockets and not for the purose of providing ancilar services,
f, Indicate, by year, for each simple cycle combustion turbine in par a,
whether any of the operational hours included in the table were for reactive
supply and voltage control or support on the PacifiCorp system,
g, Indicate, by year, for each simple cycle combustion tubine in par a, how
many ofthe operational hours included in the table were for reactive supply
and voltage control or support on the PacifiCorp system,
h, Indicate, by year, for each simple cycle combustion turbine in par a,
whether any of the operational hours included in the table were for
regulation and frequency response on the PacifiCorp system,
1. Indicate, by year, for each simple cycle combustion turbine in par a, how
many of the operational hours included in the table were for regulation and
frequency response on the PacifiCorp system,
J, Indicate, by year, for each simple cycle combustion turbine in par a,
whether any of the operational hours included in the table were for energy
imbalance on the PacifiCorp system,
PAC-E-10-07/Rocky Mountain Power
Janua 24,2011
Monsanto Data Request 19,3
k. Indicate, by year, for each simple cycle combustion turbine in par a, how
many of the operational hours included in the table were for energy
imbalance on the PacifiCorp system.
1. Indicate, by year, for each simple cycle combustion tubine in par a,
whether any of the operational hours included in the table were for spinning
reserve on the PacifiCorp system,
m, Indicate, by year, for each simple cycle combustion turbine in par a, how
many of the operational hours included in the table were for spinnng
reserve on the PacifCorp system.
Response to Monsanto Data Request 19.3
a, Simple cycle combustion turbines are Gadsby #4, Gadsby #5, and Gadsby #6,
b, The plants were conceived and engineered with AGC capabilty, but it has
never been implemented,
c, All three unts reside in a load pocket that for a few hours of each year may
have been required to serve load, Under the conditions of high retail load
and/or low generation availability that occasionally occur primarily in sumer
months, each of these generators may have been required to serve load for a
few hours each year, Such conditions are not recorded,
d, The Company made the decision, under normal conditions, to bring these
unts on-line based on economics; the unts were run if doing so was less cost
than the wholesale market price, Once the decision was made to bring the
units on line, they were also used to provide ancilary services.
e, Each hour of operation was used for serving retail load, avoiding wholesale
purchase, makng wholesale sales, and at the same time providing ancilar
services, The Company does not record these distinctions,
f. Please refer to the Company's response to Monsanto Data Request 19,3d,
g, Please refer to the Company's response to Monsanto Data Request 19.3e,
h, Please refer to the Company's response to Monsanto Data Request 19,3d,
1. Please refer to the Company's response to Monsanto Data Request 19.3e,
J, Please refer to the Company's response to Monsanto Data Request 19,3d,
k, Please refer to the Company's response to Monsanto Data Request 19,3e,
PAC-E-10-07/Rocky Mountain Power
Januar 24, 2011
Monsanto Data Request 19.3
1. Please refer to the Company's response to Monsanto Data Request 19.3d,
m, Please refer to the Company's response to Monsanto Data Request 19,3e,
Recordholder:
Sponsor:
John Apperson
Paul Clements
PAC-E-10-07/Rocky Mountain Power
Janua 24, 2011
Monsanto Data Request 19.4
Monsanto Data Request 19.4
With respect to the table at the bottom of page 8 and on page 9 in Mr, Clements'
Januar 2011 rebuttal testimony, please provide the following inormation:
a, Identify all combined cycle unts,
b, Indicate whether the combined cycle unts in par a, have Automatic
Generation Control (AGe) equipment instaled,
c, For each combined cycle unt in par a" indicate whether that combined
cycle unt resides in a load pocket on the PacifiCorp system (where a load
pocket is an area on the PacifiCorp system that, because of transmission
limitations, must have internal generation resources available because the
area canot be served entirely by external resources).
d, Indicate, by year, for each combined cycle unit in par a, whether any of the
operational hours included in the table were for serving load inside lòad
pockets and not for the purose of providing ancilar services,
e, Indicate, by year, for each combined cycle unt in par a. how many of the
operational hours included in the table were for serving load inside load
pockets and not for the purose of providing ancilar services,
f, Indicate, by year, for each combined cycle unt in par a, whether any of the
operational hours included in the table were for reactive supply and voltage
control or support on the PacifiCorp system,
g, Indicate, by year, for each combined cycle unt in par a, how many of the
operational hours included in the table were for reactive supply and voltage
control or support on the PacifiCorp system,
h, Indicate, by year, for each combined cycle unit in par a, whether any of the
operational hours included in the table were for regulation and frequency
response on the PacifiCorp system,
i. Indicate, by year, for each combined cycle unit in par a, how many of the
operational hours included in the table were for regulation and frequency
response on the PacifiCorp system,
J, Indicate, by year, for each combined cycle unit in par a, whether any of the
operational hours included in the table were for energy imbalance on the
PacifiCorp system,
k. Indicate, by year, for each combined cycle unit in par a. how many of the
operational hours included in the table were for energy imbalance on the
PacifiCorp system,
PAC-E-10-07/Rocky Mountain Power
Janua 24, 2011
Monsanto Data Request 19.4
1. Indicate, by year, for each combined cycle unit in part a, whether any of the
operational hours included in the table were for spinnng reserve on the
PacifiCorp system,
m, Indicate, by year, for each combined cycle unit in par a, how many of the
operational hours included in the table were for spinnng reserve on the
PacifiCorp system,
Response to Monsanto Data Request 19.4
a, The combined cycle unts are Curant Creek, Lake Side, Little Mountain,
Chehalis, and Hermiston.
b, Curant Creek and Lake Side have AGC equipment instaled,
c, The Curant Creek, Lake Side and Little Mountain unts reside in a load
pocket that for a few hours of each year may have been required to serve
load, Under the conditions of high retail load and/or low generation
availabilty that occaionally occur primarily in sumer months, each of these
generators may have been required to serve load for a few hours each year,
Such conditions are not recorded,
d, Please refer to the Company's response to Monsanto Data Request 19.3d,
e, Please refer to the Company's response to Monsanto Data Request 19.3e,
f, Please refer to the Company's response to Monsanto Data Request 19,3d,
g, Please refer to the Company's response to Monsanto Data Request 19,3e,
h, Please refer to the Company's response to Monsanto Data Request 19,3d,
1. Please refer to the Company's response to Monsanto Data Request i 9.3e,
J, Please refer to the Company's response to Monsanto Data Request 19,3d,
k. Pleases refer to the Company's response to Monsanto Data Request 19.3e,
1. Please refer to the Company's response to Monsanto Data Request 19.3d.
m, Please refer to the Company's response to Monsanto Data Request 19.3e,
Recordholder:
Sponsor:
John Apperson
Paul Clements
PAC-E-10-07/Rocky Mountain Power
Janua 24,2011
Monsanto Data Request 19,5
Monsanto Data Request 19.5
With respect to Mr, Duvall's Januar 2011 rebuttl testimony at page 2, line 11,
please explain in detail how the Company calculated the $73,09 per kilowatt-year
value, Include all workpapers in electronic format with all formulas intact that
ilustrate the derivation of the $73,09 per kilowatt-year value,
Response to Monsanto Data Request 19.5
Please refer to Attchment Monsanto 19,5 for the Excel Workbook that serves as
the workpapers for derivation of the $73.09 per kilowatt-year value, The
Company used its System Optimizer model to simulate portfolios with and
without the irrgation dispatchable load control resource at no cost. The model is
allowed to defer or replace the removed resource with IC aero SCCTs, firm
market purchases (front offce tranactions), and demand-side management
resources, The resource's value is determined as the year-by-year differences in
costs for the portfolios with and without the resource, converted to a 10-year
discounted levelized value, Ths approach captues the avoided energy cost and
capacity deferral value of the resource, The irrgation program was evaluated
with multiple paricipation levels, A paricipation level of 220 MW was used to
derive the $73,09 per kilowatt-year value,
Recordholder:
Sponsor:
Pete Waren
Gregory N, Duvall
PAC-E-10-07/Rocky Mountain Power
Janua 24, 2Q11
Monsanto Data Request 19,6
Monsanto Data Request 19.6
With respect to Mr, Duvall's Janua 2011 rebuttl testimony at page 2, line 19,
please explai in detail how the Company calculated the $30 per kilowatt-year
value paid to irrigators, Include all workpapers in electronic format with all
formulas intact tht ilustrate the derivation of the $30 per kilowatt-year value,
Response to Monsanto Data Request 19.6
A $30 per kilowatt-year value was negotiated with the Idao Irgation Pumpers
Association in 2007,
Recordholder:
Sponsor:
J, Ted Weston
Paul Clements
P AC-E-1 0-07/Rocky Mountan Power
Janua 24,2011
Monsanto Data Request 19,7
Monsanto Data Request 19,7
With respect to Mr. Duvall's Janua 2011 rebuttal testimony at page 3, lines 10-
17, please provide the following information:
a, Mr, Duvall's definition of "peakg units,"
b, The next unt (tye of unit and amount in MW) identified by the Company's
most recent IRP that is planed to be added to the PacifiCorp East system,
c. The year the unit identified in par b, above is planed to be added to the
PacifiCorp East system,
d, The title and date of the most recent IRP, along with page numbers,
referenced for the response to pars b, and c, above,
e, The IRP planing period assumed for the response to pars b, and c, above,
f, Does the response to par b, above assume that Monsanto's interrptible
products are economic? Explai your response in detaiL.
Response to Monsanto Data Request 19.7
a, For puroses of the IRP, peaking unts refers to simple-cycle combustion
turbines and internal combustion engines, Tables 6.2 and 6,3 (pages 102-103)
in the 2008 IR document the resource tyes evaluated.
b, The next unit to be added to the PacifiCorp system is a wet-cooled 2x1 gas-
fired combined cycle resource located in Utah, The nameplate capacity was
assumed to be 570 MW for the 2008 IRP and 607 MW for the 2008 IR
Update report.
c, The resource was planed to be added in 2014 as cited in the 2008 IRP; the
date was moved to 2015 for the 2008 IRP Update.
d, 2008 Integrated Resource Plan, May 28,2009, Table 9.1, p, 254, Integrated
Resource Plan 2008 Update, March 31, 2010, Table 5.3, p, 49,
e, The 2008 IRP planing period was 2009 though 2028, For the 2008 IRP
Update, the planing period was 2010 though 2020 in alignent with the
Company's 2010 business plan,
f. Yes, Please refer to the Company's response to Monsanto Data Request
19,8a,
Recordholder:
Sponsor:
Gregory N, Duvall
Gregory N. Duvall
PAC-E-1O-07 /Rocky Mounta Power
Januar 24,201 I
Monsanto Data Request 19,8
Monsanto Data Request 19.8
With respect to Mr, Duvall's Januar 2011 rebuttal testimony at page 4, lines 11-
13, please provide the followig information:
a, Do the 2008 IRP and 2008 IRP Update assume that Monsanto's interrptible
products are economic? Explain your response in detaiL.
b, The East Capacity Position as determined in the 2008 IR Update assuming
that Monsanto's interrptible products are economic, Include all workpapers
in electronic format with all formulas intact that ilustrate the derivation of
the East Capacity Position assuming that Monsanto's interrptible products
are economic,
c, The East Capacity Position as determined in the 2008 IRP Update assuming
that Monsanto's interrptible products are not economic, Include all
workpapers in electronic format with formulas intact that ilustrate the
derivation of the East Capacity Position assuming that Monsanto's
interrptible products are !! economic,
Response to Monsanto Data Request 19.8
a, Yes, For capacity expansion modeling puroses, the Monsanto contract is
modeled as an interrptible demand-side management product with an anual
fixed maxmum energy limit and no cost assigned, The System Optimizer
model allocates (dispatches) the energy across time periods according to when
it is optimal for decreasing the overall system cost.
b, The Company objects to the request on the grounds that it is vague,
Notwithstanding its objection, the Company interprets "economic" as a
request to fuly include the Monsanto interrptible load products in the
capacity position, Please refer to Confidential Attchment Monsanto 19,8 -1,
which shows the Company's capacity position for the east, west, and system
total. Confidential information is provided subject to the terms and conditions
of the protective order in this proceeding,
c, The Company objects to the request on the grounds that it is vague,
Notwthstading its objection, the Company interprets "not economic" as a
request to exclude the Monsanto interrptible load products from the capacity
position, Please refer to Confdential Attachment Monsanto 19,8 -2, which
shows the Company's capacity position for the east, west, and system total
after removing the Monsanto resource, Confidential information is provided
subject to the terms and conditions of the protective order in this proceeding,
P AC-E-1 0-07/Rocky Mountain Power
Januar 24,2011
Monsanto Data Request 19,8
Recordholder:
Sponsor:
Gregory N, Duvall
Gregory N, Duvall
P AC-E-1 0-07/Rocky Mountain Power
January 24, 201 I
Monsanto Data Request 19,9
Monsanto Data Request 19.9
At page 4, footnote 3 of his Januar 2011 rebuttal testimony, Mr, Duvall states the
following formula appears in the testimony ofMr, Collins:
Net Firm Obligation - Purchases - DSM - Interrptible
Please confrm or deny that this is the actual formula contaned in Mr, Collns'
testimony,
Response to Monsanto Data Request 19.9
The formula on page 4 ofMr, Collns testimony reads: "Net Firm Obligation =
Obligation - Purchases - DSM - Interrptible", The footnote in Mr, Duvall's
testimony is incorrect.
Recordholder:
Sponsor:
Gregory N, Duvall
Gregory N, Duvall