20181226PAC to IIPA 1-9.pdf

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1407 W North Temple, Suite 330
Salt Lake Cig, Utah &4116
December 26,2018
Eric L. Olsen (ISB# 481l)
ECHO HA WK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6l 19
Pocatello,Idaho 83205
[e-mail] (C)
Dr. Lance Kaufrnan
4801 W. Yale Ave.
Denver, CO 80219
[e-mail] (C)
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
tonvlOvankel.net (C)
-\/
RE: ID PAC-E-18-08
IIPA 2nd Set Data Request (l-9)
Please find enclosed Rocky Mountain Power's Responses to IIPA 2nd Set Data Requests 2.1- 2.9
Also provided is Attachment IIPA 2.1.
Sincerely,
J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Ronald L. Williams/PIIC [e-mail] (C)
Brad Mullins/PIIC [e-mail] (e-mail only)
Jim Duke/PIIC [e-mail]
Kyle Williams/PIIC [e-mail]
Val Steiner/PIIC val.steiner@.aqrium.com
Randall C. Budge/Ivlonsanto [e-mail] (C)
Thomas J. Budge/Ivlonsanto tjb@.racinelaw.net (CXW)
Maurice Brubakeri\tlonsanto [e-mail] (C)
Katie [verson/Monsanto [e-mail]
Ben Otto/ICL [e-mail] (C)
Matthew Gerhart/Sierra Club [e-mail]
Ana Boyd/Sierra Club [e-mail]
Diane Hanian/IPUC diane. holt@f uc.idaho. sov (C)
Edward Jewell/PUC edward/[e-mail]. eov
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2"d Set Data Request 2.1
IIPA Data Request 2.1
Regarding the proposed early retirement of the Cholla Unit 4, please provide the
following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(0 For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural gas prices that were used.
Response to IIPA Data Request 2.1
(a) The Company has not proposed early retirement of Cholla Unit 4 in this
docket, but has proposed to align the depreciable life of Cholla Unit 4 with its
currently established regional haze compliance obligation timeline. The
Arizona Department of Environmental Quality's (AZ DEQ) re-assessed
Aizona Regional Haze State Implementation Plan (SIP) for Cholla,
incorporating an April2025 retirement or natural gas conversion date for
Cholla Unit 4, was approved by United States (U.S.) Environmental
Protection Agency (EPA) in the Code of Federal Regulations (CFR) on March
27 , 2017 , and became effective April 26, 2017 - The Federal Register
documenting EPA's action can be accessed by utilizing the following website
link:
(b) Installation of emissions controls, natural gas conversion or early retirement
of the unit.
(c) Yes.
https://www. gpo. eov/fdsys/pke/FR-20 I 7-03 -27lpdf/20 I 7-05 724.pdf
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2''l Set Data Request 2.1
(d) Natural gas conversion remains an available option for operation of the Cholla
Unit 4 beyond the April 30,2025 regional haze compliance deadline.
(e) PacifiCorp included assessment of natural gas conversion of Cholla Unit 4 in
its2017 Integrated Resource Plan (IRP) Update filed May l, 2018. Please
refer to the discussion beginning on page 78. PacifiCorp's 2017 IRP Update
can be accessed by utilizing the following website link:
http://www.oacificom.com/content/dam/pacificorp/doc/Enerey_Sources/Intee
rated_Resource_Plan/20 I 7%20IRP%20Update/20 I 7_IRP-Update.pdf
Note: lndividual unit outcomes under any regionalhaze compliance case will
ultimately be determined by on-going rulemaking, results of litigation, and
future negotiations with state and federal agencies, partner plant owners, and
other vested stakeholders. While the regionalhaze compliance cases represent
a range of strategic paths to be evaluated, no individual unit commitrnents are
being made at this time.
(f) Please refer to Attachment IIPA 2.1 which provides copies of the forecasted
natural gas prices- utilized in the System Optimizer model (SO model) and
Planning and Risk (PaR) model for the 2017 IRP Update.
Recordholder: James Owen / Shay LaBray
Sponsor: Chad Teply / Rick Link
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2"'l Set Data Request 2.2
IIPA Data Request 2.2
Regarding the proposed early retirement of the Jim Bridger Unit l, please provide
the following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(f) For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural gas prices that were used.
Response to IIPA Data Request2.2
(a) The Company has not proposed early retirement of Jim Bridger Unit 1 in this
docket, but has proposed to align the depreciable life of Jim Bridger Unit I
with its currently assessed least-cost, least-risk alternative regional haze
compliance timeline. The United States (U.S.) Environmental Protection
Agency (EPA) approved the state of Wyoming's regional haze state
implementation plan (SIP) requirements for Jim Bridger Unit I and published
their final action in the Federal Register on January 30,2014, making the
compliance obligation legally enforceable at the federal level in addition to
being enforceable at the state level. State level compliance obligations were
established in 2010.
https://www.eovinfo.eov/content/pks/FR-2014-01-30/pdf/2014-00930.pdf
(b) Installation of emissions controls or early retirement of the unit.
(c) PacifiCorp has not considered a natural gas conversion at Jim Bridger Unit 1,
and has no unit-specific analysis associated with natural gas conversion.
(d) Please refer to the Company's response to subpart (c) above.
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2"'t Set Data Request 2.2
(e) Please refer to the Company's response to subpart (c) above.
(f) Please refer to the Company's response to subpart (c) above.
Recordholder: James Owen / Shay LaBray
Sponsor: Chad Teply / Rick Link
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2"d Set Data Request 2.3
IIPA Data Request 2.3
Regarding the proposed early retirement of the Jim Bridger Unit2, please provide
the following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(f) For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural gas prices that were used.
Response to IIPA Data Request 2.3
(a) The Company has not proposed early retirement of Jim Bridger Urut2 in this
docket, but has proposed to align the depreciable life of Jim Bridger Urrttz
with its currently assessed least-cost, least-risk alternative regional haze
compliance timeline. The United States (U.S.) Environmental Protection
Agency (EPA) approved the state of Wyoming's regional haze state
implementation plan (SIP) requirements for Jim Bridger Unit 2 and published
their final action in the Federal Register on January 30.2014, making the
compliance obligation legally enforceable at the federal level in addition to
being enforceable at the state level. State level compliance obligations were
established in 2010.
https: //www. eovinfb. eov/content/pkdFR-20 I 4-0 I -3O/pdfl20 I 4-00930.pdf
(b) Installation of emissions controls or early retirement of the unit.
(c) PacifiCorp has not considered a natural gas conversion at Jim BridgerUnrt2,
and has no unit-specific analysis associated with natural gas conversion.
(d) Please refer to the Company's response to subpart (c) above.
PAC-E-18-08 / Rocky Mountain Power
December 26,2018
IIPA 2"'l Set Data Request 2.3
(e) Please refer to the Company's response to subpart (c) above.
(f) Please refer to the Company's response to subpart (c) above.
Recordholder: James Owen / Shay LaBray
Sponsor: Chad Teply / Rick Link
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2''t Set Data Request 2.4
IIPA Data Request 2.4
Regarding the proposed early retirement of the Craig Unit 1, please provide the
following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(f) For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural gas prices that were used.
Response to IIPA Data Request2.4
(a) The Company has not proposed early retirement of Craig Unit I in this
docket, but has proposed to align the depreciable life of Craig Unit I with its
currently established regional haze compliance obligation timeline. PacifiCorp
is not the operator of Craig Unit 1, but does have a minority owner stake in
the unit. The United States (U.S.) Environmental Protection Agency (EPA)
approved the state of Colorado's regional haze state implementation plan
(SIP) requirements for Craig Unit I and published their final action in the
Federal Register on July 5, 2018, making the compliance obligation legally
enforceable at the federal level in addition to being enforceable at the state
level.
(b) Installation of emissions controls, natural gas conversion or early retirement
of the unit.
(c) Yes, as part of settlement discussions with partner owners and state / federal
agencies.
https://www.epo.eohttps://www.qpo.gov/ftlsvs/pkq/FR-2018-07-05/pdf/2018-
l4387.pdf
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2n't Set Data Request 2.4
(d) Natural gas conversion remains an available option for operation of Craig
Unit I under the terms of the regional haze compliance obligations described
above.
(e) Please refer to the Company's response to subpart (c) above.
(f) Please refer to the Company's response to subpart (c) above.
Recordholder: James Owen / Shay LaBray
Sponsor: Chad Teply / Rick Link
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2'd Set Data Request 2.5
IIPA Data Request 2.5
Regarding the proposed early retirement of the Craig Unit 2, please provide the
following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(f) For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural gas prices that were used.
Response to IIPA Data Request 2.5
(a) The Company has not proposed early retirement of Craig Unit 2 in this
docket, but has proposed to align the depreciable life of Craig Unit 2 to
facilitate least-cost, least-risk analysis, decision-making, and planning as
Craig Unit 1 approaches retirement in2025, as currently expected, and Craig
Unit 2 economics and joint owner business plaruring decisions are made..
(b) Craig Unit2 is not currently facing any major environmental compliance
requirements that would trigger major near-term capital investments.
(c) Please refer to the Company's responses to subparts (a) and (b) above.
(d) Please refer to the Company's response to subparts (a) and (b) above.
(e) Please refer to the Company's response to subparts (a) and (b) above.
(f) Please refer to the Company's response to subparts (a) and (b) above.
Recordholder: James Owen / Shay LaBray
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2nd Set Data Request 2.5
Sponsor: Chad Teply / Rick Link
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2"'l Set Data Request 2.6
IIPA Data Request 2.6
Regarding the proposed early retirement of the Craig Unit 3, please provide the
following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(f) For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural gas prices that were used.
Response to IIPA Data Request 2.6
PacifiCorp has no ownership of Craig Unit 3
Recordholder: James Owen
Sponsor: Chad Teply
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2o't Set Data Request 2.7
IIPA Data Request 2.7
Regarding the proposed early retirement of the Craig Unit 4, please provide the
following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(f) For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural' gas prices that were used.
The Craig generating station only has three units.
Recordholder: James Owen
Sponsor: Chad Teply
Response to IIPA Data Request2.T
PAC-E-18-08 / Rocky Mountain Power
December 26,2018
IIPA 2nd Set Data Request 2.8
IIPA Data Request 2.8
Regarding the proposed early retirement of the Craig Untt2, please provide the
following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(f) For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural gas prices that were used.
Response to IIPA Data Request 2.8
Please refer to the Company's response to IIPA Data Request 2.5
Recordholder: James Owen / Shay LaBray
Sponsor: Chad Teply / Rick Link
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2''t Set Data Request 2.9
Regarding the proposed early retirement of the David Johnston plant, please
provide the following:
(a) What and when were the environmental standards adopted that are associated
with the early retirement of this plant?
(b) What options were considered as a means of meeting the environment
standards listed in "a" above?
(c) Was the conversion to natural gas considered as an alternative to early
retirement of the plant?
(d) If the conversion to natural gas was considered, when was it considered?
(e) If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option
was rejected.
(f) For each time that the natural gas option was considered and rejected, please
provide a copy of the forecasted natural gas prices that were used.
Response to IIPA Data Request 2.9
The Company assumes the reference to "David Johnston" plant is intended to
reference the PacifiCorp's Dave Johnston plant. Based on the foregoing
assumption, the Company responds as follows:
(a) The Company has not proposed early retirement of the Dave Johnston plant in
this docket. The depreciable life end date for the Dave Johnston plant for
Idaho customers remains unchanged at December 31 ,2027 .
(b) Please refer to the Company's response to subpart (a) above.
(c) Please refer to the Company's response to subpart (a) above.
(d) Please refer to the Company's response to subpart (a) above.
(e) Please refer to the Company's response to subpart (a) above.
(f) Please refer to the Company's response to subpart (a) above.
Recordholder: James Owen
IIPA Data Request 2.9
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
IIPA 2''t Set Data Request 2.9
Sponsor: Chad Teply