20181119PAC to Monsanto 6, 26.pdf

Y ROCKY MOUNTAIN
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
November 16,2018
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE & BUDGE, CHARTERED
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-l 391
[e-mail] (C)
tj [e-mail] (CXW)
RE ID PAC.E-18.08
Monsanto I't Set Data Request (1-28)
Please find enclosed Rocky Mountain Power's Responses to Monsanto I't Set Data Requests
Monsanto 1.6 and 1.26. Also provided is Attachment Monsanto 26-1. Provided on the enclosed
Confidential CD are Confidential Attachments Monsanto 6 and26-2. Confidential information
is provided subject to the non-disclosure agreement between Monsanto and PacifiCorp.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J trtr
J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Diane Hanian/IPUC [e-mail] (C)
Edward Jewell/PUC Edwardj [e-mail]. gov (C)
Ronald L. Williams/PIIC [e-mail]
Jim DukelPIIC [e-mail]
Kyle Williams/PIIC [e-mail]
Val SteinerlPIIC [e-mail]
Maurice Brubaker/Ivlonsanto mbrubaker@,consultbai.com (C)
Katie Iversor/Monsanto [e-mail]
Ben Otto/ICL botto@.idahoconservation. or g (C)
Eric Olsen/IIPA [e-mail] (C)
Matthew Gerhart/S ierra C lub matt. eerhart@ sierraclub. ors
Ana Boyd/Sierra Club ana.boyd@.sienaclub.org
PAC-E-I8-08 / Rocky Mountain Power
November 16,2018
Monsanto I't Set Data Request
Monsanto Data Request 6
Please provide all correspondence between Gannett Fleming and Rocky Mountain
Power as it pertains to the depreciation study filed as Exhibit No. 2. This includes
all data requests from Gannett Fleming to RMP, all data responses from RMP to
Gannett Fleming, all email conespondence, any and all phone call notes, any and
all meeting notes, etc.
Response to Monsanto Data Request 6
The Company objects to this request to the extent it seeks information that is
protected under the attorney/client privilege or is attorney work product or is
related to the Company's expert witness work draft product. Without waiving the
objection, the Company responds as follows:
Please refer to Confidential Attachment Monsanto 6 for correspondence between
Gannett Fleming and Rocky Mountain Power.
Confidential information is provided subject to the non-disclosure agreement
between Monsanto and PacifiCorp.
Recordholder: Justus Evangelista
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 16,2018
Monsanto lst Set Data Request 26
Monsanto Data Request 26
The following questions relate to RMP Exhibit No. 6 which shows the proposed
decommissioning costs for each generating unit.
(a) Please identify the third-party that conducted these analyses.
(b) Please provide any and all correspondence between RMP and this third-party,
including all data requests, data responses, emails, meeting notes, memos,
reports, etc.
(c) Please provide all studies, reports, and work papers that support the costs
shown in this exhibit.
(d) Please explain if any of the costs included in this exhibit are included in
RMP's Asset Retirement Obligations, (ARO) for its coal plants.
(e) Please explain the level of site restoration that is included in these cost
estimates.
(f) Please explain if RMP has any legal obligation to demolish the power plants
and restore the sites consistent with assumptions used to determine these cost
estimates.
Response to Monsanto Data Request 26
(a) CB&I performed the demolition study.
(b) The Company objects to the request to the extent it seeks information that is
attorney-client privileged or expert draft work product or attomey work
product, and on the basis that it is vague and ambiguous, overly broad and
unduly burdensome. Without waiving the objection, please refer to
Attachment Monsanto 26-1.
Note: there are additional materials responsive to this request that are
considered highly confidential. The Company requests special handling.
Please contact Ted Weston at [phone] to make arrangements for
review.
(c) See the Attachment Monsanto 26-l folder for the requested information
except drawings of the generating facilities.
(d) Yes, some of the costs are included in the Company's Asset Retirement
Obligations (ARO) for its coal plants, as required by the definition of ARO.
PAC-E-18-08 / Rocky Mountain Power
November 16,2018
Monsanto lst Set Data Request 26
(e) Site restoration was described in Confidential Attachment 26-2 CONF,
"PacifiCorp - Multisite Decommissioning Design Basis 20I4I003.pdf."
Generally, site restoration included removal of all structures, foundations and
piping to a specified depth, and fuels. It also included meeting the all permit
requirements, regulated remediation requirements and asset retirement
obligations.
(0 Any legal obligation to demolish generation resources and associated site
restoration activities are governed by federal, state, and local laws,
regulations, and permits that apply contemporaneously with the potential
demolition and restoration timeframe. PacifiCorp typically proposes
demolition of units in general alignment with the retirement date of the unit
and/or the retirement data of all units on a given site due to the risk presented
by leaving unused structures in place that could pose safety hazards, security
risks, unaddressed environmental liabilities, and risks of changing
environmental rules and regulations, in particular. With regard to site
restoration the legal requirements vary by location and in terms of the site-
specific conditions at a particular property. For example, the coal combustion
residual (CCR) rule governs the closure and remediation of all landfills and
surface impoundments - this is currently implemented federally but states are
in the process of implementing state permit programs. Site specific conditions
impact the activities necessary to comply with the CCR rule. Sites that contain
other types of waste disposal must abide by the applicable rules for a
particular type of waste. Other major environmental statutes like Resource
Conservation and Recovery Act (RCRA), Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA), and the Clean Water
Act (CWA) may or may not apply depending on the site conditions, and the
company must perform site specific due diligence to ensure that it complies
with all applicable rules at the time of site restoration.
Confidential information is provided subject to the terms and conditions of the
non-disclosure a greement between Monsanto and PacifiCorp.
Recordholder: Grant Laughter
Sponsor: Chad Teply