20110929ICL to PAC 1-11.pdf

RECE!VED
Benjamin J. Otto (ISB No 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
bottocPidahoconservtion.org
2311 SEP 29 PM 3: 12
UTI
Attorney for the Idao Conservtion Leage
BEFORE THE IDAHO PUBLIC UTILITIS COMMISSION
IN TH MATTER OF THE )
APPLICATION OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER FOR )
APPROVAL OF CHANGES TO ITS )
ELECTRIC RATE SCHEDULES )
)
CASE NO. CASE NO. PAC-E-ll-12
IDAHO CONSERVATION LEAGUE'S
FIRST PRODUCTION REQUEST
COMES NOW the Idao Conservation League e'ICL") with the following
production requests. Along with the answer to each question, pleas provide any
supporting documents, workpapers, caculations, or information sources Rocky Mountai
Power ("RMP") relies upon to support its answer. As requied by IDAPA
31.01.01.228.02, please indicate the witness who ca answer question regadig the
response and who wi sponsor the response at any potential hearg. If any responses
include Excel spreadsheets or other electronic fies, please provide them with al formulas
intact and activated.
Ths production request is ongoing. Accordigly, ICL respectfuly asks RMP to
provide additional documents and information that may supplement any initial responses.
ICLs First Production
Request to Rocky Mountain
Power
1 August 29,2011
REQUEST No 1. Reference the Direct Testimony of Chad Teply at page 5. Please
provide all documents, analyses, and reports regarding any and all changes to the boilers
that were made and/or that are planned to be made to accommodate the buring of
different coals. such as higher sulfu coal - so called fuel supply flexibility - than
historically used at each coal-fired electrcal generating unit.
REQUEST No 2. Please reference the Direct Testimony of Chad Teply at page 11.
Please provide copies of the BART permits and constrction permits that "include stand-
alone requirements enforceable by the laws of the respective states" that mandate the
Company install pollution controls regardless of EPA's final review and approval of the
respective state implementation plans.
REQUEST No 3. Please reference the Direct Testimony of Chad Teply at page 12.
Please provide all analyses, documents, or reports regarding Mr. Teply's statements that
the pollution control investments in this case are required to comply with existing
regulations for the National Ambient Air Quality Standards.
REQUEST No 4. Please describe the regional haze improvements that wil result in Class
I areas from the installation of bag houses at Hunter 1, Hunter 2, Huntington 1,
Huntington 2, Dave Johnston 3, Dave Johnston 4, Naughton 3, Wyodak, and Cholla 4.
Please provide data on actul fiterable and total (filterable plus condensable) pariculate
matter emissions durng the two year before the installation of bag houses and
ICLs First Production
Request to Rocky Mountain
Power
2 August 29,2011
projections of fiterable and total pariculate matter emissions in the five years after
installation of baghouses. Please provide emissions data and estimates in terms of both
pound per milion British Thermal Unit (lb/Mtu) heat input and tons per year.
REQUEST No 5. Exhibit 29 to the Direct Testimony of Chad Teply states that Rocky
Mountain Power estimates it wil incur $68 milion in capital by 2015 and anual
operating expenses wil increase by $21 milion per year to comply with mercur
reduction requirements. Please explain, and provide all supporting documents, reports,
and analyses regarding what additional pollution control equipment (Le., beyond the
control equipment that is par of the company's application) and any changes in coal that
might be necessar for each of the Company's coal-fired electrcal generating units to
comply with the U.S. EPA's proposed MACT provisions for mercur, acid gases and
pariculate matter.
REQUEST No 6. Please provide mercur emissions data and/or mercur emissions
estimates for each of the company's coal-fired electrcal generating units in terms of
pounds of mercur emitted per milion British Thermal Unit (lb/Mtu) heat input
during 2005 to 2009.
REQUEST No.7. Please provide estimates of mercur emissions in terms of pounds per
milion British Thermal Unit (lb/MBtu) heat input for each of the company's coal-fired
units for which baghouses are to be installed as discussed in the Company's application.
ICLs First Production
Request to Rocky Mountain
Power
3 August 29,2011
REQUEST NO.8. Exhibit 29 also states the U.S. EPA's tailoring may affect futue costs
to the Company. For each of the Company's coal-fired electrcal generating units, please
provide all analyses, reports, and documents regarding whether and when the tailorig
rule would apply to each unit and for which projects the rule would apply.
REQUEST No.9. Reference the Direct Testimony of Chad Teply at page 30.
a. Please provide a list of all boiler section replacements and projects in the
category of "other" repair and replacement projects at the company's coal-fired
electrcal generating units that are included in the Company's application. Please
indicate on this list the plant, estimated cost, timeframe, and any change to the
energy output of the generating unit.
b. Please provide the Company's documents, analyses, and reports regarding the
boiler section replacement projects that are included in the Company's
application.
c. Please provide all documents, reports, and analyses as to whether the boiler
section replacement projects wil result, either directly or in combination with
other changes at the plant, in an increase in the amount of coal bured per year at
each unit and/or an increase in the maximum allowable heat input capacity of the
boiler.
REQUEST No. 10. Reference the Direct Testimony of Chad Teply at page 29.
ICLs First Production
Request to Rocky Mountain
Power
4 August 29,2011
a. Please provide all documents, analyses, and report regarding the tubine
upgrades that are included in the Company's application.
b. Please provide a copy of all documents discussing the Company's ''tbine
upgrade initiative."
c. Please provide all documents, reports, and analyses as to whether the tubine
upgrades indicated wil result, either directly or in combination with other
changes at the plant, in an increase in the amount of coal bured per yea at each
unit and/or an increase in the maximum allowable heat input capacity of the
boiler.
REQUEST No. 11. Reference the Direct Testimony of Steven McDougal at Exhibit 2
page 4.5.1. Please provide all documents regarding why the Jim Bridger tubine
upgrades are being delayed, deferred, and/or potentially cancelled.
DATED this 29th day of Augut 2011.
ßdt
Benjamin J. Otto
Idao Conservtion League
ICLs First Production
Request to Rocky Mountain
Power
5 August 29,2011
CERTIFICATE OF SERVICE
I hereby certify that on this 29th day of Aug, 2011, I delivered true and correct
copies of the foregoing IDAHO CONSERVATION LEAGUE'S FIRST PRODUCTION
REQUEST to the followig persns via the method of servce noted:
Hand delivery
Jean Jewell
Commission Secretar (Origial and three copies provided)
Idao Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
Emai only:
Rocky Mountain Power
Daniel E. Solander
Ted Weston
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
daniel.solander~pacificorp.com
ted. weston~pacificorp.com
Monsanto
Rada C. Budge
Racine, Olson, Nye, Budge & Bailey,
Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idao 83204-1391
Fax: [phone]
rcbcPracinelaw.net
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
datarequest(gpacificorp .com
Brubaker & Associates
17244 W. Cordova Cour
Sunrise, Anzona 85387
Fax: [phone]
bcollnscPconsultbai.com
IIPA
Eric 1. Olsen
Racine, Olson, Nye, Budge & Bailey,
Chartered
P.O. Box 1391; 201 E. Center
Pocatello, Idao 83204-1391
Fax: [phone]
elocPracinelaw.net
James R Smith
Monsanto Company
P.O. Box 816
Soda Sprigs, Idao 83276
Fax: [phone]
jim.r.smithcPmonsanto.com
Anthony Yankel
29814 Lae Road
Bay Vilage, Ohio 44140
Fax: [phone]
tonytyankel.net
CAPAI
Brad M. Purdy
Attorney At Law
2019 N. 17thst
Boise, Id 83702
208-384-1299
FAX: [phone]
bmpurdythotmai.com
ICLs First Production
Request to Rocky Mountain
Power
6 August 29,2011
PILC
Ronald Wiliams
Wiliams and Bradbur, P.c.
1015 W, Hays St.
Boise, ID 83702
ron cPwiiamsbradbur.com
Don Schoenbeck
RCS, Inc.
900 Washington St., Suite 780
Vancouver, WA 98660
dwscPr-c-s-inc.com
Tim Buler
PacifiCorp Idao Industrial Customers
Agrum US Inc./Nu-West Industries
tbullertagrum.com
&i ا
Benjamin J. Otto
ICLs First Production
Request to Rocky Mountain
Power
7 Augut 29,2011