20110825Staff to PAC 209-228.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
RECE erll,.,_.. ~,..-'
'lß\ \ ~UG 25 Pl' 2: 08
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-l1-12
EIGHTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilities 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 15, 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 name, location and phone number of the record holder
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 25,2011
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. 209: Please provide the remaining economic life and book value for all
coal fueled EGU's in comparson with the economic life and book value for each EGU's
emission control equipment investments reflected in PacifiCorp's Emission Reduction Plan
(Chad Teply direct testimony, Exhibit 29, page 2). For emission controls not yet implemented,
provide the remaining economic life and book values at the time the emission controls are
planed to be in service.
REQUEST NO. 210: Please provide a copy of the analysis, including all reports, work
papers, and spreadsheets with formulas intact, that supports Cathy Woollums direct testimony
(page 17, line 18) suggesting an upper limit on a cost of carbon and a lower limit on the cost of
natural gas that would indicate replacement of coal-fueled resources.
REQUEST NO. 211: Direct testimony by Cathy Woollums (page 11, line 1-6) mentions
that a number of factors are all considered in evaluating alternatives for emission compliance
investment including: system impacts, reliabilty, capital costs, operating and maintenance costs,
the life of the controls, the life of the unit itself, and cost of replacement generation. Please
provide a listing of the different alternatives evaluated for each EGU receiving emission control
upgrades during the 2011 test period and the analysis that evaluates these alternatives relative to
the above factors mentioned. Please include all analysis, reports, work papers and related
spreadsheets (with formulas intact).
REQUEST NO. 212: Please supply all award documents, reports, and analysis that
explain issues related to the hearings conducted by the American Arbitration Association (AA
Case No. 77 198 00223 10) regarding pollution control projects at Hunter #2.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 25,2011
REQUEST NO. 213: Please provide an explanation of the relationship between the
plant scrubber project investments that are "dedicated" to Naughton Unit 1 and Unit 2 and their
dependency on the fuctionality of the "common" facilties mentioned in Mr. Teply's direct
testimony (pages 19 & 20).
REQUEST NO. 214: Please provide a breakdown of the capital and anual O&M costs
(included in this rate case) for the Naughton scrubber project. Costs should be broken down by
investments "dedicated" to units #1 and #2 and by "common" facilties mentioned in Mr. Teply's
direct testimony (pages 19 & 20). Costs should also be broken down by the timing of each
investment as it relates to their in-service date.
REQUEST NO. 215: Please provide an explanation of the relationship between the
plant scrubber project investments that are "dedicated" to Hunter Unit 1 and Unit 2 and their
dependency on the fuctionality of the "common" facilties mentioned in Mr. Teply's direct
testimony (page 24).
REQUEST NO. 216: Please provide a breakdown of the capital and anual O&M costs
(included in this rate case) for the Hunter scrubber project. Costs should be broken down by
investments "dedicated" to units #1 and #2 and by "common" facilities mentioned in Mr. Teply's
direct testimony (page 24). Costs should also be broken down by the timing of each investment
as it relates to their in-service date.
REQUEST NO. 217: Are there any other "common" emission control related
investments that are being implemented in the 2011 test period that are shared and used by
emission control facilities put into operation in a time period later than the 2011 test period? If
so, please provide a breakdown of costs similar to what was requested for the Naughton and
Hunter facilties.
REQUEST NO. 218: Please provide an explanation of the changes in the tons of S02
removed and incremental $Iton removed ofS02 for Hunter Unit #2 and Huntington Unit #1
shown in exhibit 27 of Chad Teply's direct testimony as compared to the same analysis shown in
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 25, 2011
Chad Teply's Rebuttal (Table 1) and Surrebuttl (Table 2) testimony in Utah Docket 10-035-
124. In addition to the explanation, please provide all sources of information used to conduct the
analyses, supporting documents, and spreadsheets (with formulas intact).
REQUEST NO. 219: Has the Company ever performed a net present value cost study
(or other similar apples-to-apples comparison) that compares continued operation of each
retrofitted coal fueled generation unit examined in this rate case with alternatives that would be
considered least cost replacement capacity for the EGU in question? Alternatives would include
both supply side (in addition to the conversion of an existing coal plant to a natural gas plant
which the Company has already supplied) and demand side options. If so, please provide a copy
of the analysis, reports, and spreadsheets (with formulas intact).
REQUEST NO. 220: Please provide the five factor BART analysis/evaluations (see
Cathy Woollums direct testimony, page 4, lines 22-23 and page 5, lines 1-3) for each EGU that
determined the Company's emission control investments included in Wyoming and Utah's SIP's.
REQUEST NO. 221: Please provide a ten year history (actual/measured) and a ten year
forecast of anual S02, NOx, and PM emissions (tons/year) for each plant (and unit) listed in
Pacificorp's Emission Reduction Plan (Chad Teply direct testimony, Exhibit 29, page 2). Please
reflect the timing of past and future installations/upgrades of emission controls (with a short
description) on each char or table.
REQUEST NO. 222: Please provide a comprehensive accounting of all future
(including test year investments) facilty costs and upgrades (including end-of-life replacement
costs) for each plant (and unit) listed in PacifiCorp's Emission Reduction Plan (Chad Teply
direct testimony, Exhibit 29, page 2).
REQUEST NO. 223: With respect to each of the categories listed in the Company's
response to Staff Production Request No. 38, how many kWh had not been biled prior to the
time a new customer signed up for service?
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 25,2011
REQUEST NO. 224: With respect to each of the categories listed in the Company's
response to Staff Production Request No. 39, how many kWh had not been biled prior to the
time a new customer signed up for service?
REQUEST NO. 225: In response to Staff Production Request No. 45, the Company
states that for a total of 4,096 residential accounts, it took more than five (5) days for a new
customer to sign up for service. For these accounts, please provide a more specific timeframe for
Schedules 1 and 36 as follows: (a) 30 days or less; (b) 31-60 days; (c) 61-90 days; (d) more than
90 days. In each of these time frames, how many accounts accumulated usage of 1000 kWh or
more before a new customer signed up for service?
REQUEST NO. 226: For project SHTN/20111C/004 U2 Boiler Finishing SH Pendants
Replacement, please provide a schedule of milestones, due date for those milestones, and
payments associated with those milestones. Also please provide the invoice amounts and dates
of those invoices.
REQUEST NO. 227: Please reference Company responses to Production Requests No.
56 and 57 regarding land and plant sales. Please calculate the benefit to be passed back to Idaho
customers. If the benefit to Idaho customers has already been included within the filing, please
identify where and in what accounts. If there is no benefit to be passed back to Idaho customers
please specifically identify why not. Please include within your response the calculation method
and Idaho allocator.
REQUEST NO. 228: Please update the Company's salary adjustment to reflect the
actual ratification/effective dates of the agreements referenced on Exhibit 2, Page 4.3.6. Please
include within your response all the workpapers and resulting adjustment as revised for this
change.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 25, 2011
DATED at Boise, Idaho, this rs;?day of August 2011.
rJ3-~
Neil Price
Deputy Attorney General
Technical Staff: Mike Louis/209-222
Marilyn Parker/223-225
Joe Terry/226
Patricia Hars/227-228
i:umisc:prodreq/pacel 1.2np prod req8
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 AUGUST 25, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF AUGUST 2011,
SERVED THE FOREGOING EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER,
IN CASE NO. PAC-E-ll-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.westonêpacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solanderêpacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
dataequestCfacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbêracinelaw.net
BRUBAKER & ASSOCIATES
16690 SWIGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: beollnsêconsultbai.com
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithêmonsanto.eom
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: eloêracinelaw.net
ANTHONY Y ANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
E-MAIL: tonyêyanel.net
BRAD MPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyêhotmail.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: bottoêidahoconservation.org
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS STREET
BOISE ID 83702
E-MAIL: ronêwiliamsbradbury.com
DON SCHOENBECK
RCS INC
900 WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: dwsêr-c-s-inc.com
CERTIFICATE OF SERVICE
E-MAIL: ONLY
TIM BULLER
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS
AGRIUM US INCINU- WEST INDUSTRIES
E-MAIL: tbullerêagrium.com
SEC~R~
CERTIFICATE OF SERVICE