20170925Utah_DPU Set 9 (1-14).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PACIFICORP
September 11,2017
Erika Tedder
Division of Public Utilities
160 E 300 S,4th Floor
Salt Lake City,UT 84114
etedder@utahgoy (C)
RE:UT Docket No.17-035-39
DPU 9th Set Data Request (1-14)
Please find enclosed Rocky Mountain Power's Responses to DPU 9th Set Data Requests 9.1-
9.14.Provided on the enclosed Confidential CD are Confidential Attachments DPU 9.7 and 9.13
and Confidential Responses DPU 9.7 and 9.14.Confidential information is provided subject to
Public Service Commission of Utah (UPSC)Rules 746-1-602 and 746-1-603.
If you have any questions,please call Tarie Hansen at [phone].
Sincerely,
Bob Lively
Manager,Regulation
Enclosures
C.c.:Dan Kohler/DPU [e-mail](C)
Dan Peac/DPU M (C)(W)
Aliea Afnan/DPU (W)
[e-mail] (W)
Béla Vastag/OCS bvastag@utah ov (C)
Philip Hayet/OCS [e-mail] (C)
Gary A.Dodge/UAE gdodge h dlaw.com (C)
Kevin Higgins/UAE (C)
Neal Townsend/UAE (C)(W)
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.1
DPU Data Request 9.1
Link Testimony.In reference to Mr.Link's Testimony,Exhibit 3:
9.1.1.Please provide the portion of the "Cost of Project"row that represents the
Company's return on the investment in the repower project,on both an annual and
present value basis.Provide work papers supporting the calculation in electronic
spreadsheet format with formulas intact.
9.1.2.If applicable,please provide references to the work papers provided supporting
the Link Testimony containing the source numbers provided in response to part
(a).
Response to DPU Data Request 9.1
(1)Please refer to the Company's response to subpart (2)below.
(2)All confidential work papers supporting the Direct Testimony of Company witness,
Rick T.Link,have been provided.Using Dunlap as an example,the return on
investment is initiallycalculated in the tab "Generic",row 1731 ("Rate of Return"):
Folder:"Wind Projects\Linked Repower"
File:"IRP Repower LGIA Limit vl3 WIC Dunlap"
This row of data is then included in the calculation of "Capital Recovery (Repower
Investment)"in the followingconfidential work paper:
Folder:"Other Summary Reports"
File:"RePower Data 20170516 LGIA Limit vl3"
Please refer to the tab "Dunlap",row 10.This row of values is then added to the
"Capital Recovery (Repower Investment)"data for all repower resources,calculated
in the tab "Summary"of this same workbook,again on row 10.
The tab "Summary"data in row 10 is then included in the confidential work paper
where the "Cost of Projects"is calculated:
Folder:"Exhibits Figures Tables"
File:"Repower Results Direct Testimony"
Please refer to the tab "Price-Policy Annual -SO",examine the formulas provided in
any "Cost of Project"row,such as cell E56.This value is presented in tab "Exhibit
3",cell E49,where the "SO Model Annual Results ($million)"data is summarized.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.1
The above referenced confidential work paper trace also applies to the "Price-Policy
Annual -PaR""Cost of Project"data,represented in the lower section of tab
"Exhibit 3".
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.2
DPU Data Request 9.2
Link Testimonv.In reference to Mr.Link's Testimony,Exhibit 5:
9.2.1.Please provide the portion of the "Capital Recovery"row that represents the
Company's return on the investment in the repower project,on both an annual and
present value basis.Provide work papers supporting the calculation in electronic
spreadsheet format with formulas intact.
9.2.2.If applicable,please provide references to the work papers provided supporting
the Link Testimony containing the source numbers provided in response to part
(a).
Response to DPU Data Request 9.2
(1)Please refer to the Company's response to DPU Data Request 9.1 subpart (2).
(2)Please refer to the confidential work paper trace provided in the Company's response
to DPU Data Request 9.1,noting that the reference to row 10 in the tab "Summary"
of the confidential file "RePower Data 20170516 LGIA Limit vl3"instead refers to
row 73 of the same tab.The same underlyingreturn on investment is included in row
73.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.3
DPU Data Request 9.3
Link Testimony.In reference to Mr.Link's Testimony,Lines 303-334,describing the $7
million increase in the risk-adjusted PVRR in the case without Leaning Juniper:
9.3.1.Which price-policy scenario yielded the $7 million result?
9.3.2.Please provide all results listed in Tables 2 and 3 of the Link testimony with and
without Leaning Juniper.
Response to DPU Data Request 9.3
(1)The two cases compared to calculate the $7 million benefit for repowering Leaning
Juniper used the medium gas,medium carbon dioxide (CO2)price-policy assumption.
(2)The Company objects to this request as requiring developmentof a special study or
information not maintained in the ordinary course of business.Without waiving this
objection,the Company responds as follows:
The Company did not conduct Leaning Juniper sensitivities for additional price-
policy scenarios or for extended benefits beyond the 2017 through 2036 study period.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.4
DPU Data Request 9.4
Please provide a benefit/cost ratio for the addition of Leaning Juniper to the repowering
project.Provide work papers supporting the calculation in electronic spreadsheet format
with formulas intact.
Response to DPU Data Request 9.4
The Company objects to this request as requiring development of a special study or
information not maintained in the ordinary course of business.Without waiving this
objection,the Company responds as follows:
PacifiCorp has not conducted a cost/benefit ratio for the addition of Leaning Juniper.
PacifiCorp analyzed includingthe Leaning Juniper wind project in its 20-year portfolio
optimization studies and compared the present-valuerevenue requirements (PVRR)of a
case with the addition of Leaning Juniper and without Leaning Juniper.The case with the
addition of Leaning Juniper produced a risk-adjusted system PVRR that was
approximately $7 million lower than the case without Leaning Juniper.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.5
DPU Data Request 9.5
Link Testimony.In reference to Mr.Link's Testimony,Lines 303-334,describing the
$20 million reduction in the risk-adjusted PVRR in the case with GoodnoeHills:
9.5.1.Which price-policy scenario yielded the $20 million result?
9.5.2.Please provide all results listed in Tables 2 and 3 of the Link testimony with and
without GoodnoeHills.
9.5.3.Please provide a benefit/cost ratio for the addition of Goodnoe Hills to the
repowering project.Provide work papers supporting the calculation in electronic
spreadsheet format with formulas intact.
Response to DPU Data Request 9.5
Please note that the incremental benefit of GoodnoeHills presented in the confidential
work papers supporting the Direct Testimony of Company witness,Rick T.Link,is
$18 million,and was incorrectlystated as $20 million in Mr.Link's Direct Testimony.
Please refer to the Company's response to DPU Data Request 7.1.
(1)The two cases compared to calculate the $18 million benefit for repowering Goodnoe
Hills used the medium gas,medium carbon dioxide (CO2)price-policy assumption.
The Company objects to subparts 9.5.2 and 9.5.3 as requiring development of a special
study or information not maintained in the ordinary course of business.Without waiving
this objection,the Company responds as follows:
(2)The Company did not conduct GoodnoeHills sensitivities for additional price-policy
scenarios or for extended benefits beyond the 2017 through 2036 study period.
(3)PacifiCorp has not conducted a cost/benefit ratio for the addition of Goodnoe Hills.
PacifiCorp analyzed includingthe Goodnoe Hills wind project in its 20-year portfolio
optimization studies and compared the present-valuerevenue requirements (PVRR)
of a case with the addition of Goodnoe Hills and without GoodnoeHills.The case
with the addition of GoodnoeHill produced a risk-adjusted system PVRR that was
approximately $18 million lower than the case without GoodnoeHills.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.6
DPU Data Request 9.6
Regarding the Company's response to DPU 3.19,is the Company intending to make any
investments to extend the lives of the towers and additional 10 years beyond their design
life?If so,please provide all estimates of expected costs and supporting documentation
for these values.
Response to DPU Data Request 9.6
No.The Company does not anticipate that additional investments beyond standard
maintenance will be necessary to extend the tower lives.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.7
DPU Data Request 9.7
Please provide all results listed in Tables 2 and 3 of the Rick Link testimony excluding
the costs of the WindFREE and WindINERTIA equipment.
Confidential Response to DPU Data Request 9.7
The total cost of WindFREE and WindINERTIA equipment included in the projects is
cost
2,
benefit wouldapply to all of the values in Table 3.
Please refer to Confidential Attachment DPU 9.7,which provides modified work papers
excluding the costs of the WindFREE and WindINERTIA equipment.Table 2 and
Table 3 summaries are presented in the confidential file "Repower Results Direct
Testimony less equip".
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.8
DPU Data Request 9.8
In reference to DPU's Data Request question 1.3.5,please state the warranty period for
the WTG gearboxes at each of the Company's wind plants.Are the gearboxes covered
as part of the OEM warranty?If not,please provide the terms of any other maintenance
agreement or warranty terms and conditions with respect to the gearboxes.
Response to DPU Data Request 9.8
Please refer to the Company's response to DPU Data Request 2.6,specifically
Confidential Attachment DPU 2.6-2,which contains the original equipment
manufacturer warranty terms.Yes,the wind turbine generator gearboxes were covered
as part of the OEM warranties.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.9
DPU Data Request 9.9
In reference to the Company's Data Request response 1.3.5,Goodnoe Hills'information
was not included.Please provide the information that was asked for in question 1.3.5 for
Goodnoe Hills.
Response to DPU Data Request 9.9
DPU Data Request 1.3,subpart 5,requested information about gearboxes that are
experiencing premature failure as described in the Direct Testimony of Company witness,
TimothyJ.Hemstreet.These gearbox types are not present at the GoodnoeHills facility,
and therefore there is no information related to Goodnoe Hills that is responsive to the
request.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.10
DPU Data Request 9.10
Did the Company perform any due diligent efforts after the early failures of the
gearboxes?For example,did the Company talk to the suppliers about the high failure
rates?Did the Company negotiateany liabilityclaims or other recourse actions to cover
the costs to replace future failing gearboxes by either GETS or Rexroth?What due
diligence has the Company performed on the repowered equipment to ensure that the
gearboxes do not fail?Please describe the Company s efforts.
Response to DPU Data Request 9.10
The Company has examinedthe root cause of gearbox failures since the expiration of the
original equipment manufacturer (OEM)warranties and related full-service agreements.
The Company began activelytracking and analyzing each gearbox failure in the wind
fleet in 2012 to determine failure modes,investigate preventative maintenance and
diagnostic measures that may be used to avoid gearbox failures or reduce their rate of
occurrence or severity to minimize equipment down time and repair and replacement
costs.The Company has actively participated in the National Renewable Energy
Laboratory (NREL)Gearbox Reliability Collaborative since 2012,and Company staff
have participated in its meetings since that time to better understand gearbox failure
modes,failure rates,preventative measures,and gearbox component improvements.The
Company has discussed the high failure rates with the equipment suppliers but has not
successfully negotiated liabilityclaims for equipment failures outside the original
warranty period.
Regarding the new repowering equipment,the Company has confirmed with the suppliers
that the gearbox models experiencing high failure rates will not be part of the repowered
turbines.The Company has also discussed with the suppliers the gearbox reliability
testing and qualification measures and improvements in gearbox design that have been
incorporated into the repowering turbine designs.Additionally,the Company is
purchasing third-partytechnology reviews of the repowering turbines to evaluate
potential issues with the new equipment.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.11
DPU Data Request 9.11
How much does the Company anticipate spending on repairs and maintenance of the
current wind fleet if it does not repower?
Response to DPU Data Request 9.11
Please refer to the Company's response to DPU Data Request 1.9,specifically
Confidential Attachment DPU 1.9.In the spreadsheet "Wind Repower OMAG (May 16
2017)CONF,"the Company's estimated operations and maintenance (O&M)costs for
the wind fleet assuming repowering does not take place are shown in cells F25 through
AC36.In the spreadsheet "Wind Repower CAPEX (May 10 2017)CONF,"the
Company's estimated run-rate capital expendituresfor the wind fleet assuming
repowering does not take place are shown in cells F26 through AC27 of the "CAPEX
MODEL INPUTS"tab.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.12
DPU Data Request 9.12
Please provide all geotechnical,engineering,or other reports proving that the current
WTG towers and foundations will sustain new repowered equipment.
Response to DPU Data Request 9.12
Please refer to the Company's response to DPU Data Request 1.9,in which the Company
provided the available foundation-review memos for the wind projects for which
foundation loads are now available.Please also refer to the Company's response to DPU
Data Request 3.21,detailing that the equipment suppliers are responsible for confirming
the suitabilityof the existing towers and that this design suitabilitywill be confirmed
through a third-partycertification.The Company intends to seek permission to disclose
additional informationthat cannot be disclosed without the supplier's express written
permission.The Company will supplement the request when permission is granted or if
new data becomes available.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.13
DPU Data Request 9.13
Please provide details of all payments made to GE and Vestus since May of 2016.
Response to DPU Data Request 9.13
The Company assumes that the reference to "Vestus"is intendedto reference Vestas
American Wind Technology Inc.(Vestas).Based on this assumption,the Company
responds as follows:
Please refer to Confidential Attachment DPU 9.13.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.14
DPU Data Request 9.14
Please provide the equipment inventorylists of the current wind fleet.
Note:the Division of Public Utilities (DPU)provided a restated request for DPU Data
Request 9.14 on September 7,2017.The restated request is set out below:
For each of the Company's wind plant projects,please provide the annual inventorylist
of the followingWTG components from the past 10 years.For each item,please identify
(1)how many are in stock,(2)where is it being stored,and (3)the assumed dollar values
of (a)through (f).
(a)Rotor blade.
(b)Gearbox.
(c)Hub.
(d)Nacelle.
(e)Generator.
(f)Brake.
Confidential Response to DPU Data Request 9.14
The Company objects to this request to the extent it requires development of a special
study or informationnot maintained in the ordinary course of business.Withoutwaiving
this objection,the Company responds as follows:
The Company interprets this data request as seeking information on the historical
inventoryof capital spare parts for the wind turbine generator components listed above
that have been maintained by the Company and the associated costs.Given the long lead
times associated with procuring replacement components,the Company generally plans
to stock one to two capital spares for rotor blade sets,gearboxes and generators.The
Company does not maintain capital spare parts for hubs,nacelles or brakes.The
approximate'costs of rotor blades,gearboxes and generators for the different wind
turbine generator equipment used in the Company's wind fleet are:
1 Costs are approximate since prices vary by availability and do not include variable costs associated with freight,
delivery,and offloading.
17-035-39 /Rocky Mountain Power
September 11,2017
DPU Data Request 9.14
Capital Spare Part Costs*(in $1,000s)
Wind Plant Rotor Blades*Gearbox**Generator
Goodnoe Hills (Senvion)
Leaning Juniper,Glenrock /Rolling Hills,Seven Mile
Hill I /Seven Mile Hill II,High Plains /McFadden
Ridge,Dunlap (General Electric (GE))
*Rotor blades are generally purchased in sets of three blades.Costs shown are for single blades.
**Gearboxes for the GE fleet are purchased with a main shaft since the entire drivetrain assembly is replaced with the gearbox.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.