20120724Staff 9-19 to PAC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
2012 JUL 24 AM 10: 37
iDAHO PUBLft MSSlJ
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S )
APPLICATION FOR AN ACCOUNTING )
ORDER REGARDING COSTS INCURRED )
FOR NAUGHTON UNIT 3. )
)
)
)
CASE NO. PAC-E-12-07
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, by TUESDAY, AUGUST 14, 2012.
This Production Request is to be considered as continuing, and the Company 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 24, 2012
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 9: Please describe the process for selecting the engineering,
procurement and construction (EPC) contractor. Your description should include how the
vendor was selected resulting in a contract (i.e. competitive bidding, etc.) that was the lowest
possible cost.
REQUEST NO. 10: Please provide copies of monthly progress reports from the EPC
contractor.
REQUEST NO. 11: Please explain the cost difference between the (a) EPC Contract
Cost in Attachment 1 to the Application, and (b) the Maximum Cumulative Progress Payment
Amount for a February cancellation date as shown in the EPC contract.
REQUEST NO. 12: Please describe the Dry Ash system study (as shown in Attachment
1 to the Application). The description should include the study's purpose (what it is and why it
is important to the overall project), a list of the major deliverables, and a timeline of the major
milestones. Please also state what percentage of the study was complete when the suspension of
work was issued, and the total estimated cost.
REQUEST NO. 13: Please describe the Landfill siting study (as shown in Attachment 1
to the Application). The description should include the study's purpose (what it is and why it is
important to the overall project), a list of the major deliverables, and a timeline of the major
milestones. Please also state what percentage of the study was complete when the suspension of
work was issued, and the total estimated cost.
REQUEST NO. 14: Please describe the Pulse Jet Fabric Filter (PJFF) system studies (as
shown in Attachment 1 to the Application). The description should include the study's purpose
(what it is and why it is important to the overall project), a list of the major deliverables, and a
timeline of the major milestones. Please also state what percentage of the study was complete
when the suspension of work was issued, and the total estimated cost.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 24, 2012
REQUEST NO. 15: Please describe the best available retrofit (BART) study (as shown
in Attachment 1 to the Application). The description should include the study's purpose (what it
is and why it is important to the overall project), a list of the major deliverables, and a timeline of
the major milestones. Please also state what percentage of the study was complete when the
suspension of work was issued, and the total estimated cost.
REQUEST NO. 16: Please generally describe the scope of work for each contract under
the category of "Owner's engineering consulting contracts" shown in Attachment 1 to the
Application. What was the process used to select each contractor to ensure lowest possible cost?
What was the total estimated cost and the percent of completion for each contract when the
suspension of work was issued?
REQUEST NO. 17: Please provide Rocky Mountain's targeted (or estimated) level of
emissions that it believes it will need to achieve compliance at the Naughton facility for the
following environmental regulations:
a.Regional Haze Rules (BART)
b.Mercury Toxics Standards (MATS/MACT)
c.National Ambient Air Quality Standards (NAAQS)
d.Coal Combustion Residuals (CCR)
e.Water Impingement Standards (Clean Water Act 316(b))
Please provide this for each individual generation unit, for the entire Naughton facility, or
both, depending on the method required by permitting agencies. For clarity purposes, please
describe if the permits for each regulation will be (or assumed to be) issued by each individual
generation unit or for the entire facility.
REQUEST NO. 18: Please provide a breakdown by generating unit of usage and capital
investment for common infrastructure/equipment that is required to use coal as a fuel.
REQUEST NO. 19: Please list the capital investments (including estimated dollar
amounts) that could/would be leveraged as common facilities by Naughton units #1 and/or #2 if
they were converted to natural gas. Please include a utilization breakdown by generating unit.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 24, 2012
DATED at Boise, Idaho, this i '1ay of July 2012.
I I z 41-1
Karl T. Klein
Deputy Attorney General
Technical Staff: Mike Louis/9-19
i:umisc:prodreq/pace12.7kkm1 prod rcq3
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 24, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF JULY 2012,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-12-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
YVONNE HOGLE
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: Yvonne.hog1e(pacificorp.com
SECRETARY
CERTIFICATE OF SERVICE