20110818Staff 194-208 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
RECEIVED
23ti AUG 18 PH 2: 31
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE SCHEDULES )
)
)
)
)
CASE NO. PAC-E-ll-12
SEVENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information on or before
THURSDAY, SEPTEMBER 1,2011.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the nåme, location and phone number of the record holder
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 18,2011
and, if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO. 194: According to Mark T. Widmer's direct testimony for WIEC and
Cindy A. Crane's rebuttal testimony included in Wyoming Docket 20000-384-ER-1O, the
Company agreed to adjust fines and related legal fees levied on the Company by the Federal
Mine Safety and Health Administration on Bridger Coal Company from fuel expenses. Were
Idaho's allocation of the fines levied on Bridger Coal Company and associated legal fees
removed from the fuel expense for the test period in this case? If so, please provide
documentation that these costs were removed. If not removed, please provide a breakdown of
the associated cost.
REQUEST NO. 195: Besides fines levied on Bridger Coal Company by the Federal
Mine Safety and Health Administration, were there any other costs related to fines or citations
levied on the Company or its affliates that were not reduced from test period expenses in this
i
casb? If so, please provide a breakdown of the associated cost.
¡
REQUEST NO. 196: Please provide all contracts, calculations, memorandum and other
relevant documentation supporting the pro forma December 2011 overhaul prepayment amounts
separately identified by plant (Lake Side, Chehalis and Currant Creek) included within the
Company's filing on Exhibit 2, page 8.7.1, Item 2.
REQUEST NO. 197: Please provide the underlying accounting documents and
supporting information (payment request andother documentation submitted to initiate the
prepayment) for the December 2011 overhaul prepayment amounts separately identified by plant
(Lake Side, Chehalis and Curant Creek) included within the Company's filing on Exhibit 2,
page 8.7.1, Item 2.
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 18,2011
REQUEST NO. 198: Please provide all contracts, calculations, memorandum and other
relevant documentation supporting the actual December 2010 overhaul prepayment amounts
separately identified by plant (Lake Side, Chehalis and Currant Creek) included within the
Company's filing on Exhibit 2, page 8.7.1, Item 2.
REQUEST NO. 199: Please provide the underlying accounting documents and
supporting information (payment request and other documentation submitted to initiate the
prepayment) for the actual December 2010 overhaul prepayment amounts separately identified
by plant (Lake Side, Chehalis and Currant Creek) included within the Company's fiing on
Exhibit 2, page 8.7.1, Item 2.
REQUEST NO. 200: For each project listed on Exhibit 2, page 8.6.2 (Major Plant
Additions) please provide a copy of the most recent contractor request for payment including all
the supporting documentation for that contractor request (amounts biled to date, percentage of
completion by task, and other information required of the contractor for request for
reimbursement and/or payment under the contract). If the plant has been placed in service, this
document package is expected to be the final contractor request for payment under the contract.
If it is not, please identify why not.
REQUEST NO. 201: In addition to the Response to Staff Production Request No. 104,
for each of the plant additions listed in the Company's response to IPUC Production Request No.
102, please provide a listing, by transaction, of all expenditures incured from inception of the
project to date separately for each plant addition. Please include within your response the
invoice (or other transaction identifier ifit is not an invoice) number, description of payment,
payee name (field may be blank if there is no individual payee), date and amount posted.
REQUEST NO. 202: Please reference Exhibit 2, page 8.6.2 (Major Plant Additions).
For the Naughton Unit 2 NOx LNB - Clean project, please provide a copy of the major contracts
underlying the project.
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 18,2011
REQUEST NO. 203: In addition to the Response to Staff Production Request No. 167,
for each of the incremental operation and maintenance expenses included in Exhibit 2,
Adjustment 4.13, please provide a listing, by transaction, of all expenditures incured to date
during 2011. Please include within your response the invoice (or other transaction identifier if it
is not an invoice) number, description of payment, payee name (field may be blan if there is no
individual payee), date and amount posted.
REQUEST NO. 204: Reference Response to Monsanto Production Request No. 2.67.
Please provide the revenue requirement change that would be associated with both the Tier 1 and
Tier 2 Coal Supply Agreements. Please provide schedules and workpapers showing at least the
following detailed information: tonnage, price per ton, sharing ratios and amounts associated
with PacifiCorp's piece, account numbers and line item impacts by account for all changes in the
revenue requirement.
REQUEST NO. 205: Please provide documentation demonstrating how Project
DZSLl2008/C/0091B Skyark Build New 138-12.5kV Substation benefits Idaho customers.
REQUEST NO. 206: Please provide a reconciliation of the amount included in this Rate
Case (IPUC Production Request No. 102) and the amount of expenses accrued to date (including
contractor and in house expenses) for the following Major Plant Additions:
. TUTM/2006/C/031/B Mona Limber Oquirr 500/345kVTanssLn
. TZKL/2008/C/00IIB Malin 500 kV series cap replacement
TZCE/2007/C/004IB Red Butte Static Var Compensator and 345 kV Shunt Capacitor.
. TIID/2007/C/002/B Populus-Terminal: Dbl Ckt 345 kV TransLn - Transmission
. TIID/2007/C/002IB Populus - Terminal 345 kV line - Borah Reconductor
. HNUQ/2006/C/008/029 INU 6.1 Lemolo 2 Reroute to Toketee
. HNUQ/2009/C/008/009 INU 4.1.1 (t)/6.9 Slide Tailrace Barrier
. HIDA/2006/C/003/002 Procure / Construct Tunel
. SNAU/2008/C/C05 NAU U2 Flue Gas Desulfurization Sys
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 18,2011
REQUEST NO. 207: Reference Exhibit No.2, page 4.11. Durng the on-site audit in
Salt Lake City, Staff received a one page explanation of the Adjustment to Tax. Please provide
schedules and workpapers calculating the figures provided on that sheet, supporting
documentation and explanations of the adjustments.
REQUEST NO. 208: Please provide a revised Response to Staff Production Request
No. 102 separating the amounts for Populus - Terminal between Transmission and Borah
Reconductor similar to Exhibit No.2, page 8.6.2.
DATED at Boise, Idaho, this ~day of August 201 1.
_..~
Neil Price
Deputy Attorney General
Technical Staff: Mike Louis/194-195
Patricia Hars/196-204
Joe Terr/205-208
i:umisc:prodreq/pacel1.2np prod req7
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 18,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF AUGUST 2011,
SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER,
IN CASE NO. PAC-E-11-12, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MGR
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.westoninpacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solanderinpacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datarequestinpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbinracinelaw.net
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: bcollnsinconsultbaLcom
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithinmonsanto.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: eloinracinelaw.net
ANTHONY Y ANKEL
29814 LAK ROAD
BAYVILLAGEOH 44140
E-MAIL: tonyinyanel.net
BRAD MPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyinhotmail.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: bottoinidahoconservation.org
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 WHAYS STREET
BOISE ID 83702
E-MAIL: roninwillamsbradbury.com
DON SCHOENBECK
RCS INC
900 WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: dwsinr-c-s-inc.com
CERTIFICATE OF SERVICE
E-MAIL: ONLY
TIM BULLER
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS
AGRIUM US INC/NU- WEST INDUSTRIES
E-MAIL: tbullerinagrium.com
JD~SECRETAY~
CERTIFICATE OF SERVICE