20120815PAC to Staff No.9-19.pdf

Mark C.Moench (ISB#8946)
Daniel E.Solander (ISB#8931)
Rocky Mountain Power
201 South Main Street,Suite 2300
Salt Lake City,Utah 84111
Telephone No.[phone]
Facsimile No.[phone]
Email:[e-mail]
Attorneyfor Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)IN THE MATTER OF PACIFICORP DBA )ROCKY MOUNTAIN POWER’S )CASE NO.PAC-E-12-07
APPLICATION FOR AN ACCOUNTING )ORDER REGARDING COSTS INCURRED )ATTORNEY’S CERTWLCATEFORNAUGHTONUNIT3)CLAIM OF CONFIDENTIALITY
)RELATING TO DISCOrERY
)RESPONSES
)
)
I,Daniel E.Solander,represent Rocky Mountain Power in the above captioned matter.I
am Senior Counsel for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding responses to the attached
discovery request and response IPUC Staff 10 pursuant to IDAPA 3 1.01.01 because Rocky
Mountain Power,through its supporting workpapers,is disclosing certain information that is
Confidential and constitutes Trade Secrets as defmed by Idaho Code Section 9-340 and 48-801
and protected under IDAPA 31.01.01.067 and 31.01.01.233.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the information contains commercially sensitive contractor progress reports.Disclosing this
information could give entities access to competitive information Rocky Mountain Power
believes could be used to disadvantage it and its customers.
1
I am of the opinion that this information is “Confidential,”as defmed by Idaho Code
Section 9-340 and 48-80 1,and should therefore be protected from public inspection,examination
and copying.
DATED this 14th day of August,2012.
Respectfully submitted.
By___
Daniel E.Solander
Attorneys for Rocky Mountain Power
2
VI ROCKY IVIOUNTAIN --r——,201 South Main,Suite 2300
POWER L Salt Lake City,Utah 84111
A DVISON O PACIFICORP —
¶z-J
August 14,2012
VIA EMAIL
AND OVERNIGHT DELIVERY
Kristine A.Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 W.Washington
Boise,ID 83702-5918
[e-mail]
RE:ID PAC-E-12-07
IPUC Data Request (9-19)
Please find enclosed Rocky Mountain Power’s responses to IPUC Data Requests 9-19.Also
provided electronically is Attachment IPUC 18.Provided on the enclosed Confidential CD are
Confidential Attachments IPUC 10 —(1-2).
If you have any questions,please feel free to call me at [phone].
Sincerely,
J.Ted Weston
Manager,Regulation
Enclosure
C.c.:Jean Jewell/IPUC Jean.jeweIl(puc.idaho.gov (3 CDs)
Tern Carlock/IPUC Tern .Canlock@pucJdaho gov (W)
PAC-E-1 2-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 9
IPUC Production Data Request 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.
Response to IPUC Production Data Request 9
The Company’s formal request for proposals (“RFP”)was based on a template
contract,template contract exhibits,project schedule,technical specification and
conceptual design drawings.RFP packages were distributed to prequalified
technology providers,engineering organizations and construction contractors.In
order to perform the comprehensive requirements of the RFP and project,the
market responded via proposal teams that generally included a technology
provider(s),engineer and constructor.The Company completed a comprehensive,
competitive bid evaluation and contract negotiation undertaking to establish the
risk adjusted least cost respondent.Proposals were received from four entities.
Evaluation concepts included:(1)meeting minimum qualifications,(2)as-bid
pricing,(3)scope pricing adjustments,(4)life cycle pricing adjustments,(5)
commercial terms and conditions and (6)technical performance.
Recordholder:Richard Goff
Sponsor:To Be Determined
PAC-E-1 2-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 10
IPUC Production Data Request 10
Please provide copies of monthly progress reports from the EPC contractor.
Response to IPUC Production Data Request 10
Monthly EPC contractor progress reports received from the EPC contractor for
December 2011 and January 2012 are provided as Confidential Attachments
IPUC Production 10-1 and IPUC Production 10-2 Monthly progress reports for
other periods were not produced by the EPC contractor.
Recordholder:Richard Goff
Sponsor:To Be Determined
PAC-E-12-.07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 11
IPUC Production Data Request 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.
Response to IPUC Production Data Request 11
The difference between the (b)“maximum cumulative progress payment amount”
for a February 2012 cancellation date and the (a)Attachment 1 EPC contract cost
work breakdown structure (“WBS”)(SNAU/2009/C/071!EPC)is the addition of
associated indirect charges for allowance for funds used during construction
(“AFUDC”).
Recordholder:Richard Goff
Sponsor:To Be DetermirLed
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 12
IPUC Production Data Request 12
Please describe the Dry Ash system study (as shown in Attachment I 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 maj or milestones.Please also state what percentage of the study
was complete when the suspension of work was issued,and the total estimated
cost.
Response to IPUC Production Data Request 12
The purpose ofthe study was to:
•evaluate the feasibility of alternative ash handling technologies that could
be utilized to collect and store dry or dewatered coal combustion residuals
(“CCR”)for transport to a new dry landfill facility;
•identify preferred pipe routing corridors to storage facilities;
•develop process flow diagrams and arrangements for each alternative;
•evaluate the effect of each alternative on unit operations and maintenance,
auxiliary power,and site water management;and
•develop initial capital and operational and maintenance costs for each
viable alternative.
CCR evaluated in the study included pyrites,bottom ash,and fly ash from all
three units.
Completion of the study was critical to effectively establish the design basis and
specify the Pulse Jet Fabric Filter fly ash disposal system and to site a landfill.
During the study it was established that the dry landfill location for this CCR
would be located on Naughton plant property and would be positioned either
immediately north or south of the power block.Therefore arrangements for CCR
handling technologies were based on both locations.
The study work occurred during the period from December 2010 through April
2011 and was 100 percent complete at the time of project suspension.
The total cost for this study is $135,895.04,as posted on July 30,2012 in SAP
project systems.(Reference work breakdown structure (“WBS”)element:
SNAU/2009/C/07 1/DRYASH)
Recordholder:Richard Goff
Sponsor:To Be Determined
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 13
IPUC Production Data Request 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.
Response to IPUC Production Data Request 13
This study addressed landfill siting alternatives for dry disposal offly ash from
the proposed Pulse Jet Fabric Filter (“PJFF”)instead of interconnecting the
system to the existing wet fly ash sluicing system that discharges into an existing
surface impoundment.The EPA is currently evaluating new rules for disposal of
coal combustion residuals (“CCR”)and this study determined the risk adjusted
least cost alternative for future PIFF fly ash disposal assuming Subtitle D proxy
provisions are adopted,along with concurrently looking at associated plant wide
effects.
Major tasks completed during this study included:
•review of available reference data related to:
o existing CCR ponds,
o existing ground water monitoring wells and data,
o projected CCR volumes,and
o existing construction and operating permits;
•evaluation ofpermitting,design and construction requirements for CCR
dry landfills in the following potential locations:
o onsite landfills located on undeveloped Naughton plant property,
o conversion of the existing wet ash ponds (surface impoundments)
to dry landfills,
o potential purchase ofproperties adjoining the Naughton plant
property for siting a new landfill(s),
o development of offsite landfills on nearby PacifiCorp property not
contiguous to the Naughton plant;
•identify closure requirements of the existing wet ash disposal ponds;
•establish operational and maintenance requirements for a new dry landfill
facility;
•establish closure requirements for a new dry landfill facility;
•address dry ash transportation effects,including:
o develop conceptual designs for ash haul roads from the point of
loading to disposal,
o coordination with others on selecting the preferred location for the
proposed PJFF fly ash collection silo,
PAC-E-1 2-O7IRocky Mountain Power
August 14,2012
IPUC Production Data Request 13
o establish effects for haulage on public road to offsite disposal
locations;
•develop feasibility level initial capital cost estimates for each landfill
siting alternative;
•develop a project schedule timeline for each landfill siting alternative;and
•compare alternatives and offer specific recommendations.
The study work occurred during the period from January 2011 through April 2011
and was 100 percent complete at the time of project suspension.
Total cost for this study is $139,560.32 as posted on July 30,2012 in SAP project
systems.(Reference work breakdown structure (“WBS”)element:
SNAU/2009/C/07 1ILANDF)
Recordholder:Richard Goff
Sponsor:To Be Determined
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 14
IPUC Production Data Request 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.
Response to IPUC Production Data Request 14
Costs included under “/BHDEVTR”consist of contracted activities such as early
project investigations regarding existing plant conditions,sulfur dioxide reduction
opportunities,BART studies,BART modeling,and baghouse retrofit concepts.
The costs were transferred from PJFF development WBS SNAUI2008ICICO6,
NAU U3 S02 and PM Emissions Control Upgrade.Costs were originally posted
to SAP in 2007-2011 and pointed to SNAUJ2008/C/C06.
The work occurred during 2007 to 2011,costs were transferred to the project in
2011-2012,and was 100 percent complete at the time ofproject suspension.
Total cost for this work is $324,191.47 as posted on August 14,2012 in SAP
project systems.(Reference WBS element:SNAU/2009/C/07 1IBHDEVTR).
Recordholder:Richard Goff
Sponsor:To Be Determined
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 15
IPUC Production Data Request 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 tiineline of the major milestones.Please also state what percentage ofthe
study was complete when the suspension of work was issued,and the total
estimated cost.
Response to IPUC Production Data Request 15
Costs included under BARTSTY2 are associated with modeling,agency reviews
and BART studies completed to support PacifiCorp’s BART permit application to
the Wyoming DEQ and requested contributions to the Wyoming State
Implementation Plan.
Environmental requirements to install Selective Catalytic Reduction and Pulse Jet
Fabric Filter investments on Naughton Unit 3 are reflected in three separate,but
related,mandates:(i)Permit No.MI)-6042 (BART permit for the Naughton
Plant);(ii)the BART Appeal Settlement Agreement dated November 3,2010;and
(iii)the Wyoming 3 09(g)Regional Haze State Implementation Plan dated January
7,2012.
The study work was 100 percent complete at the time ofproject suspension.
Total cost for this WBS is $68,258.46 as posted on July 31,2012 in SAP project
systems.(Reference WBS element:SNAU/2009/C/07 1 /BARTSTY2)
Recordholder:Richard Goff
Sponsor:To Be Determined
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 16
IPUC Production Data Request 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?
Response to IPUC Production Data Request 16
The Owner’s Engineer (“OE”)contract for work associated with PacifiCorp’s
comprehensive air initiative was competitively procured.
During the project development phase,the OE deliverables included the:
•design basis document (Naughton Unit 3,SCR and Baghouse Study
Report,December 23,2009);
•technical specification for bid (Technical Specification No.N-5003,bid
(November 24,2010),addendum,and issued for contract (December 2,
2011)versions;and
•participation in the EPC contract bid evaluation.
All OE development work occurred prior to project suspension.
The total cost as posted on July 31,2012 in SAP project systems is $836,701.84.
(Reference:WBS SNAU/2009/C/071/CONSULT)
During the project implementation phase,the OE’s work included:
•review and comment on technical submittals from the EPC contractor with
regard to conformance with technical specification requirements,contract
documents and good engineering practice;
•participation at site meetings with PacifiCorp and the EPC contractor,
including the project kickoffmeeting(s)and project progress review
meetings;
•participation during regular project team telephone conferences scheduled
by PacifiCorp and the EPC contractor;and
•assisting PacifiCorp with evaluation of EPC scope changes.
OE implementation phase work was suspended approximately the same time as
the EPC contract suspension.One additional invoice for $3,929.00 was received
for work completed in March 2012.
The total cost as posted on July 31,2012 in SAP project systems is $107,563.14.
(Reference:WB S SNAU/2009/C/07 1/CONSULT)
Recordholder:Richard Goff
PAC-E-12.O7IRocky Mountain Power
August 14,2012
IPUC Production Data Request 16
Sponsor:To Be Determined
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 17
IPUC Production Data Request 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.
Response to IPUC Production Data Request 17
a.Regional Haze Rules (BART)
Operation within the following unit-specific emission limits which are
required by the BART permits and construction permits issued by the state of
Wyoming will demonstrate compliance with the Regional Haze Rules
(BART),and Wyoming’s 309 and 3 09(g)State Implementation Plans.
NOx Limits PM Limits SO2 Limits
Unit lb/MMBtu lb/MMBtu lb/MIVifitu
Naughton Unit 1 0.26 0.040 0.15
Naughton Unit 2 0.26 0.040 0.15
Naughton Unit 3 0.07 0.0 15 NA
The Unit 3 limits shown are based on the replacement of that unit’s existing
electrostatic precipitator with a fabric filter baghouse and the installation of
selective catalytic reduction (SCR)as currently required by the BART permit.
If the baghouse and SCR projects are not completed,this unit’s compliance
with the Regional Haze Rules (BART)will be accomplished by converting
the unit from coal to natural gas.
b.Mercury and Air Toxics Standards (MATS/MACT)
Operation within the following unit-specific mercury emission limits will
demonstrate compliance with the Mercury and Air Toxics Standards
(MATS/MACT)for that pollutant.The limits shown in the table are codified
in the Federal Register.The limits identified in the Federal Register will be
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 17
incorporated into each unit’s operating conditions when the Title V operating
permit is renewed.
Mercury
Emissions Acid Gases Non-Hg Metals
Unit (lb/TBtu)(lb/MMBtu)(lb/MMBtu)
Naughton 1 2 0.0020 HCI or 0.030 Filterable PM or
Unit 1 0.20 SO2 0.00005 for total non-Hg metals
Naughton 1,0.0020 HC1 or 0.030 Filterable PM or
Unit 2 0.20 SO2 0.00005 for total non-Hg metals
Naughton 1 2 0.0020 HCI or 0.030 Filterable PM or
Unit 3 0.20 SO2 0.00005 for total non-Hg metals
c.National Ambient Air Quality Standards (NAAQS)
the area around the plant has not been classified as a non-attainment area for
any pollutant.It is expected that by operating within the following unit-
specific emission limits the area will continue to be in attainment with the
National Ambient Air Quality Standards (NAAQS).
Emission Limits
__________Naughton Unit 1 Naughton Unit 2 Naughton Unit 3
PM]PM10 74 lb/hour 96 lb/hour 56 lb/hour
NOx 481 lb/hour 624 lb/hour 259 lb/hour
SO2 833 lb/hour 1,080 lb/hour 1,850 lb/hour
CO 463 lb/hour 600 lb/hour NA
The Unit 3 limits are based on the replacement of the existing electrostatic
precipitator with a fabric filter baghouse and the installation of selective
catalytic reduction (5CR).If the baghouse and SCR projects are not
completed,the unit will be converted to natural gas,which will result in lower
emissions and support maintenance of the National Ambient Air Quality
Standards.
d.Coal Combustion Residuals (CCR)
The EPA’s Coal Combustion Residuals (CCR)rule has not been finalized at
this time.,Currently a final rule is expected in early 2012.Compliance with
the final rule,when issued,will not be contingent upon unit-specific or plant-
wide emissions.Compliance will be based upon the practices and procedures
that the plant uses to store and manage the plant-generated coal combustion
and scrubber process waste materials.
PAC-E-12-O7IRockv Mountain Power
August 14,2012
IPLTC Production Data Request 17
e.Water Impingement Standards (Clean Water Act 316(b))
The EPA’s Clean Water Act Section 316(b)cooling water intake structure
niles have not been finalized.Currently,the fmal rulemaking is scheduled to
be completed by June 27,2013.Compliance with the final nile,when issued,
will not be contingent upon unit-specific or plant-wide emissions.Compliance
will be based on the performance of the Naughton plant’s water intake
structure as measured against the applicable standard(s)that are fmalized.
Recordholder:Bill Lawson
Sponsor:To Be Determined
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 18
IPUC Production Data Request 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.
Response to IPUC Production Data Request 18
Please refer to Attachment IPUC Production 18,which generally describes the
plant common systems as they are shared by the three units.In general,Units 1
and 2 share boiler support utilities with Unit 3,but the scrubber systems are
separated.The actual use of most commodities is measured,but allocation of the
balance of costs of certain common process systems is proportional to the rated
capacities (MW)of the units.If Unit 3 were to no longer burn coal,the operating
costs of certain common systems that no longer serve that unit would be
reallocated to Unit I and Unit 2.
The process systems and common infrastructure required to operate any one of
the three units independently or all three together is generally described in
Attachment IPUC Production 18.The rate base value associated with these
operational plant systems and common facilities is accounted for under the
appropriate FERC codes if there is interest in a particular cost category.
Recordholder:Steve Richards
Sponsor:To Be Determined
PAC-E-12-07/Rocky Mountain Power
August 14,2012
IPUC Production Data Request 19
IPUC Production Data Request 19
Please list the capital investments (including estimated dollar amounts)that
couldiwould 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.
Response to IPUC Production Data Request 19
The Company has not performed any analysis for a natural gas conversion of
Naughton Units 1 and 2.New capital investments being planned for Naughton
Unit 3 natural gas conversion would primarily provide the unit-specific natural
gas fuel line downstream of the plant metering station,natural gas burners and
controls.
Any new gas pipeline infrastructure required from the existing mainline to the
plant metering station would be provided by the natural gas supplier and the
associated costs included in fuel transportation costs from the supplier.The
current gas supplier for the Naughton site has indicated that they will be able to
provide the gas for Unit 3 without maj or changes to their system.If Units 1 and 2
are converted to natural gas,the increase in gas may require changes in the natural
gas delivery system upstream of the plant metering station.The costs for such
upgrades would be incorporated into commercial supply agreements negotiated at
the time.As such,there is little to no leveraging the proposed Unit 3
infrastructure to enable the conversion of Units 1 and 2 at a later time.
Recordholder:Steve Richards
Sponsor:To Be Determined
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