20130308PAC to Monsanto 1-19.pdf

'ROCKY MOUNTAIN
POWER
A DMSION OF PAOROfiP
March 7, 2013
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2flI 3 VIA R_.8 AM 8:51
UAHO PU01L(: I
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201 South Main, Suite 2300
Salt Lake City, Utah 84111
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
[e-mail] (C)
RE: ID PAC-E-13-03
Monsanto Data Request (1-19)
Please find enclosed Rocky Mountain Power's responses to Monsanto Data Requests 1-19,
excluding 10 and 13. These responses will be provided separately. Also provided are
Attachments Monsanto 1, 2 -1, 15, 16, and 17. Provided on the enclosed Confidential CD are
Confidential Attachments 2 -2, 4, 6, 9, Il, 12, and 14. Confidential information is provided
subject to the terms and conditions of the protective agreement in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jean D. Jewell, Secretary jean.iewellpuc.idaho.gov (C)
Ted Weston/Rocky Mountain Power [e-mail] (W)
Daniel Solander/Rocky Mountain Power [e-mail] (W)
Data Request Response Center/PacifiCorp [e-mail] (W)
Maurice Brubaker/Monsanto [e-mail] (C)
Katie Iverson/Monsanto [e-mail] (C)
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 1
Monsanto Data Request 1
Please provide a copy of all data requests received from Commission Staff and
other parties. Please consider this to be a continuing request and supplement your
response as additional requests are received.
Response to Monsanto Data Request 1
Please refer to Attachment Monsanto 1.
Recordholder: N/A
Sponsor: N/A
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 2
Monsanto Data Request 2
Please provide a copy of your responses to the data requests from Commission
Staff and other parties. Please consider this to be a continuing request and
supplement your response as additional requests are received.
Response to Monsanto Data Request 2
Please refer to Attachment Monsanto 2 -1 and Confidential Attachment Monsanto
2 -2. Confidential information is provided subject to the terms and conditions of
the protective agreement in this proceeding.
Recordholder: N/A
Sponsor: N/A
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 3
Monsanto Data Request 3
Please provide a copy of your responses to requests conveyed to Rocky Mountain
Power other than through formal data requests from Commission Staff and other
parties. Please consider this to be a continuing request and supplement your
response as additional requests are received.
Response to Monsanto Data Request 3
At this time there have been no requests outside the formal data request process.
Recordholder: N/A
Sponsor: N/A
PAC-E-13.-03IRocky Mountain Power
March 7, 2013
Monsanto Data Request 4
Monsanto Data Request 4
Direct Testimony of Brian S. Dickman: For line 15 of "ID Actual Loads" of
Exhibit 1, please provide all supporting workpapers used in the development of
the monthly energy amounts. Also, please provide a narrative of how and where
these loads are metered, measured and adjusted, if so.
Response to Monsanto Data Request 4
Please refer to Confidential Attachment Monsanto 4.
Referencing the Direct Testimony of Company witness, Brian S. Dickman;
specifically Confidential Exhibit 1, the data from line 15 of "ID Actual Loads"
comes from the Jurisdictional Load System (JLS). In the JLS calculation, Idaho
load is a calculation of interchanges, borderlines, generation, state border
crossings, and scheduled losses.
Each interchange point is added into the calculation. An interchange point is a
metered point between two control areas. Power moving into the control area
adds to the load; power moving out of the control area subtracts from the load.
Each borderline point adds to the calculation. A borderline can be inside or
outside the control area. Inside the control area, a borderline consists of a third
party load (UAMPS, UMPA, etc). Outside the control area, a borderline consists
of PacifiCorp load in another control area. Borderline meters outside our control
area are added to the load; borderline meters inside our control area are subtracted
from the load.
All generation is metered and adds to the load calculation.
State border crossings are metered and used to divide up the control area net
system load into its constituent jurisdictions.
Losses that are scheduled to other control areas to cover PacifiCorp losses outside
PacifiCorp' s control area are added to the load. Losses that are scheduled to
PacifiCorp to cover others' losses on PacifiCorp's system are subtracted from the
load.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 5
Monsanto Data Request 5
Direct Testimony of Brian S. Dickman: For line 26 of "ID Actual Loads" of
Exhibit 1, please provide an explanation of the large percentage differences
shown for the adjustment factors, both positive and negative. Please expand this
explanation beyond the standard explanation that these loads are developed for
different purposes and with different methodologies. For example, does the
Company have any explanation why adjustment factor is 23% in June, and -13%
in August? Are there different assumptions as to customer load? Does the
Company still maintain that these differences are entirely due to moving
wholesale energy?
Response to Monsanto Data Request 5
The Company maintains the differences are primarily attributable to moving
wholesale energy. Generally speaking, the variance between JAM loads and COS
loads is attributable to the different methods used to develop the loads. JAM
loads reflect metered jurisdictional loads. Class loads in the cost of service study
are developed from sample and direct census Load Research data and not adjusted
for irrigation curtailment or temperature. Also, the loss factors employed vary,
i.e., class loads are adjusted by a static loss factor, and jurisdictional loads reflect
actual losses.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 6
Monsanto Data Request 6
Direct Testimony of Brian S. Dickman: Please provide a summary which includes
the amount and an explanation of each adjustment made to actual NPC to derive
adjusted actual NPC for the ECAM test year.
Response to Monsanto Data Request 6
The total reduction to actual net power costs (NPC) of $9,420,315 consists of five
components: Sacramento Municipal Utility District (SMUD) normalization,
removal of special contract curtailment buy-through, Black Cap solar allocation,
coal cost adjustments, and other out of period adjustments.
SMUD Normalization
The SMUD normalization adjustment reduced actual NPC by $5,795,231. This
adjustment reflects Idaho Public Utilities Commission's ratemaking treatment for
SMUD that imputes a $3 7IMWh sales price on the firm sales and applies a market
price on the provisional transactions made under the contract.
Removal of Special Contract Curtailment Buy-Through
The removal of special contract curtailment buy-through reduced actual NPC by
$2,557,530. This adjustment is required to remove the effects of special contract
customers consuming energy during curtailment events. Buy-through energy is a
direct pass-through cost to special contract customers and should have no impact
toNPC.
Black Ca Solar Allocation
The Black Cap solar allocation adjustment increased actual NPC by $12,936. This
adjustment removes the impact of zero cost energy generated by the Black Cap
solar facility by applying a market price to the generation output. Consistent with
the 2010 Protocol, the Black Cap solar facility is situs assigned to Oregon because
it was acquired pursuant to an Oregon state-specific initiative. The benefit and
cost associated with the Black Cap solar facility are not included in Idaho rates
and the energy should not impact the energy cost adjustment mechanism
(ECAM).
Coal Cost Adjustments
Coal cost adjustments reduced actual NPC by $480,180. These adjustments are
necessary to remove legal fees related to fines and citations, and to remove of
accounting entries at the Company's coal facilities related to periods prior to the
inception of the ECAM.
Other Out of Period Adjustments
Other out of period adjustments reduced actual NPC by approximately $600,311.
These adjustments represent accounting transactions booked during the ECAM
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 6
test year but that are related to operating periods prior to the inception of the
ECAM. Please refer to Confidential Attachment Monsanto 6, which provides a
list of the out of period entries making up this adjustment.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03IRocky Mountain Power
March 7, 2013
Monsanto Data Request 7
Monsanto Data Request 7
Direct Testimony of Brian S. Dickman: Please provide a comparison of all
budgeted thermal planned outages and actual planned outages in MWh by plant
for the ECAM test period, including a detailed explanation of why individual
plant budgets were exceeded for outages that exceeded budgets by 5,000 MWh or
more.
Response to Monsanto Data Request 7
ECAM Test Period: December 2011 - November 2012
Plant
Budgeted
Planned Outage
MWh
Actual Planned
Outage MWh
Actuals that exceed
budget by more than
5,000 MWh
Blundell 7,320 7,705
Carbon 0 0
Chehalis 245,904 290,717 44,813
Cholla 4 0 0
Coistrip 284,160 408,258 124,098
Craig 0 0
Currant Creek 582,552 609,207 26,655
Dave Johnston 332,640 342,799 10,159
Gadsby 57,960 216,959 158,999
Hayden 123,648 579,208 455,560
Hermiston 202,656 222,162 19,506
Hunter 441,140 410,090
Huntington 0 0
Jim Bridger 534,189 683,559 149,370
Lake Side 52,800 23,021
Naughton 252,816 321,546 68,730
Wyodak 0 0 1
Chehalis:
The Chehalis facility was originally scheduled for planned outage during June of
2012 for a total of 480 hours. The outage ended up being taken in late October
through mid Novembers for a total of about 596 hours. During the course of the
overhaul, a borescope inspection revealed that Combustion Turbine #1
compressor stator and rotor blade had damage likely from domestic object
damage (DOD). GE recommended immediate repairs on the blading at various
locations which kept the facility off-line for an extended period of time.
Colstrip:
PAC-E-13-03IRocky Mountain Power
March 7, 2013
Monsanto Data Request 7
Coistrip No. 3 unit was originally scheduled for planned outage during May of
2012 for a total of 384 hours. The outage ended up running for a total of about
552 hours. The additional hours were primarily due to a lack of demand for the
unit to produce energy. All overtime hours were suspended and some additional
work was performed that wouldn't necessarily have kept the unit from going back
into service, but nevertheless was done to take advantage of being off-line.
Currant Creek:
In the early part of December 2011, the entire facility was on a planned outage for
a state mandated HRSG Drum Inspection which took a little over 120 total hours.
The timing of this activity was something that was un-budgeted.
In 2012, the Currant Creek facility was scheduled for a planned outage in October
and November. Both gas turbines were planned to be off for a total of 1,080
hours as well as the steam turbine. Due to contractor scheduling, both gas
turbines were in overhaul from late September through mid November for a little
over 1,000 hours. The steam turbine was off concurrently with the combustion
turbines with a slightly extended duration of about 1,040 hours. The reason for
the steam turbine overage was due to generator voltage control issues.
Dave Johnston:
The Dave Johnston No. 4 unit was originally scheduled on a planned outage
during the months of March - April of 2012 for a total of 1,009 hours. The unit
ended up being off-line for this planned outage for about 1,039 hours. The short
overage on this outage is primarily due to startup issues associated with boiler
ignitors and excitor relay testing requirements.
Gadsby:
An unanticipated planned outage on Gadsby No. 5 took place for about 32 hours
in December of 2011 to replace an SCR catalyst. The Gadsby No. 2 unit was
originally scheduled for planned outage during February - March of 2012 for a
total of 840 hours. Gadsby No. 2 unit did have an overhaul that took place in
February - March for a total of 863 hours. In addition to the original scope of
activity, the no. 2 unit ended up being extended for an additional 2,226 hours due
to a rewind of the generator. Gadsby No. 4 was scheduled for planned outage to
replace NOx catalyst. The duration was 26 hours. A planned outage on Gadsby
units 4 -6 occurred in June to wash turbine compressor. The duration was 3
hours each. A planned outage on Gadsby 4-6 occurred in April to modify the
water supply system. The duration was 15 hours.
Hayden:
Hayden No. 2 unit came down for an unanticipated planned outage during
December of 2011 that ran for nearly 192 hours. The Hayden No. 1 unit was
originally scheduled for a planned outage during the month of March 2012 for a
total of 672 hours. The No. 1 unit did have a planned outage during the March -
May period of 1,487 hours with a follow-up planned extension of another 1,022
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 7
hours due to the rewind of the generator. Unit 2 was off-line for an unanticipated
planned outage in the fall of 2012 for 141 hours. Unit 1 also came off-line for an
unanticipated fall outage in November 2012 for about 165 hours. The primary
reason for the overage can be attributed to a failed hypot test on unit 1 which
resulted in a rewind of the stator.
Hermiston:
Hermiston No. 1 unit was scheduled for a planned outage during the September -
October 2012 period for a total of 672 hours. There ended up being an
accelerated outage during the April - May 2012 time frame of 720 hours with a
follow up (unanticipated) planned outage in the fall of an additional 66 hours.
Hermiston No. 2 unit was originally scheduled for 192 hours during the
September - October 2012 time frame. The outage was accelerated to the June
2012 time frame with a duration of about 168 hours. The combustion inspection
on unit 2 actually finished on time. The overage on unit l's major overhaul is
primarily due to additional time required for stator wedges that needed further
adjustment.
Jim Bridger:
Jim Bridger 4 unit was budgeted for 1,008 hours of planned outage in the April -
May time frame of 2012. The No. 4 unit was down for 1,056 hours for the
original scope of the budgeted outage and two additional extensions of 200 and 33
hours respectively. The primary reasons for the extended planned outages can be
attributed to:
1.There were design and installation issues on the original boiler scaffolding.
The original scaffolding had to be stabilized, removed, and re-installed. This
lead to an extension of the overhaul of approximately 6 days (144 hours).
2.The balance of the outage extension (approximately 89 hours) can be
attributed to the boiler contractor missing the scheduled water tight date,
delays in the nose arch replacement project and a tube leak discovered during
hydro testing of the boiler.
Naughton:
Naughton No. 1 unit was budgeted for a major overhaul during the March - May
period of 2012 for a total of 1,585 hours. The actual overhaul period ran from
March - mid June for a total of about 1,977 hours. Additionally, there were three
more short planned outages for various tests which lasted about 32 hours. The
primary reason for the additional 392 hours above and beyond the original
planned outage scope was the increase in the scope of work required to complete
boiler stiffening. There was time included in the outage schedule to stiffen the
boiler casing to reduce furnace implosion risk due to the installation of the
scrubber and booster fan on the unit. However, once the outer covering on the
boiler was removed to allow this work to begin, areas were discovered that had
severe bowing. This had a serious impact on the scope of work to properly stiffen
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 7
the boiler casing. Additionally, the asbestos removal on the inner boiler casing
was more involved than originally planned and took longer than anticipated.
Recordholder: Dean Harmon
Sponsor: Brian Dickman
PAC-E-13-03IRocky Mountain Power
March 7, 2013
Monsanto Data Request 8
Monsanto Data Request 8
Direct Testimony of Brian S. Dickman: Please list any Company thermal plant
outage for a particular NERC outage code that exceeded the industry average for
like kind plants for the ECAM test year. If the Company exceeded the industry
average for a particular NERC code, please provide the total MWFI exceeded.
Response to Monsanto Data Request 8
The NERC data for calendar year 2012 is not yet available nor has the Company
done an analysis to determine how its performance relative to certain NERC
codes compares with industry experience. To do that would be unduly
burdensome and time consuming. In 2012 the Company's equivalent availability
factor (EAF) for its coal operated system was 89.7 percent, overall historical
performance on EAF and capacity factor has outperformed the industry. The
Company believes these broader performance metrics are better measures of its
position than any selected group of NERC codes would indicate. The enclosed
chart is indicative of these standard measures of performance over a period of the
last several years where the Company has consistently outperformed the industry.
95 -r--------------
90 +--------------
PacifiCorp vs. N ERC
Equivalent Availability Factor & Capacity Factor
Coal Operated System
48 Month Rolling Averages
- NERC Equiv. Avalabilty Factor • NERC Capacity Factor
PaciflCorp Equiv. Availability Factor PacifiCorp Capacity Factor
75
70
65 -_.....
60
2005-2008 2006-2009 2007-2010 2008-2011 2009-2012
48 Month Rolling Average Periods
Please note that the 48 month rolling averages are based on a similarly configured
system of industry-based coal-fired units.
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 8
Recordholder: Dean Harmon
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 9
Monsanto Data Request 9
Direct Testimony of Brian S. Dickman: Please provide a copy of all internal
reports that discuss operational problems with any component of the Company's
generation fleet during the ECAM test year.
Response to Monsanto Data Request 9
Please refer to Confidential Attachment Monsanto 9. Confidential information is
provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder: Dean Harmon
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 11
Monsanto Data Request 11
Direct Testimony of Brian S. Dickman: Please provide a monthly summary of the
amount of thermal generation lost from forced outages during the ECAM test year
and a step by step discussion of how the information was calculated.
Response to Monsanto Data Request 11
Please refer to Confidential Attachment Monsanto 11. Confidential information
is provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder: Dean Harmon
Sponsor: Brian Dickman
PAC-E-13-O3IRocky Mountain Power
March 7, 2013
Monsanto Data Request 12
Monsanto Data Request 12
Direct Testimony of Brian S. Dickman: Please provide a copy of the Company's
hourly generation logs by plant for the ECAM test year.
Response to Monsanto Data Request 12
Please refer to Confidential Attachment Monsanto 12. Confidential information
is provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 14
Monsanto Data Request 14
Direct Testimony of Brian S. Dickman: Please provide the hourly contingency
reserves (spin and ready) carried on each resource during the ECAM test year.
Response to Monsanto Data Request 14
Please refer to Confidential Attachment Monsanto 14. Confidential information
is provided subject to the terms and conditions of the protective agreement in this
proceeding.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 15
Monsanto Data Request 15
Direct Testimony of Brian S. Dickman: Please provide the electric and natural gas
forecasts used in the base NPC as described at line 1, page 11 of Mr. Dickman' s
testimony.
Response to Monsanto Data Request 15
As described in the Direct Testimony of Company witness, Brian S. Dickman, the
base net power cost (NPC) during the energy cost adjustment mechanism
(ECAM) deferral period originated from two rate cases:
Case No. PAC-E-10-07 and Case No. PAC-E-1 1-12.
Please refer to Attachment Monsanto 15 for the electricity and natural gas price
forecast used in Case No. PAC-E- 10-07 and the electricity and natural gas price
forecast used in Case No. PAC-E-11-12.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 16
Monsanto Data Request 16
Direct Testimony of Brian S. Dickman: Please provide the actual wholesale
electricity and natural gas prices for the deferral period referenced by Mr.
Dickman at line 22, page 10 and line 1, page 11 of his testimony. Please provide
actual monthly average numbers for all pricing hubs.
Response to Monsanto Data Request 16
Please refer to Attachment Monsanto 16.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 17
Monsanto Data Request 17
Direct Testimony of Brian S. Dickman: Please provide all workpapers supporting
the statement at lines 2-3, page 11 of Mr. Dickman' s testimony.
Response to Monsanto Data Request 17
Please refer to Attachment Monsanto 17.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 18
Monsanto Data Request 18
Direct Testimony of Brian S. Dickman: Please provide Monsanto access to all
GRID models supporting the direct testimony of Mr. Dickman.
Response to Monsanto Data Request 18
The Direct Testimony of Company witness, Brian S. Dickman does not rely on
any GRID modeling. GRID is utilized by the Company to forecast normalized net
power costs (NPC) for a rate case test period; it is not used to report actual NPC.
Actual NPC are recorded by FERC account in the Company's accounting system.
This FERC account information has been extracted and summarized in
Confidential Exhibit No. 1 to Mr. Dickman's Direct Testimony.
Recordholder: Brian Dickman
Sponsor: Brian Dickman
PAC-E-13-03/Rocky Mountain Power
March 7, 2013
Monsanto Data Request 19
Monsanto Data Request 19
Direct Testimony of Brian S. Dickman: Please provide copies of all GRID model
inputs for all GRID models supporting the direct testimony of Mr. Dickman.
Response to Monsanto Data Request 19
Please refer to the Company's response to Monsanto Data Request 18.
Recordholder: Brian Dickman
Sponsor: Brian Dickman