20200930PAC to Monsanto Responses 35-38.pdf

ROCKY MOUNTAIN
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
Septernber 30,2020
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 83204-1391
r andy @r acineol son. com (C)
tj @racineolson. com (C)(lV)
RE: ID PAC-E-18-08
Monsanto 3'd Set Data Request (35-39)
Please find enclosed Rocky Mountain Power's Responses to Monsanto 3d Set Data Requests 35-
39. Also provided is Attachment Monsanto 35. Provided on the enclosed Confidential CD are
Confidential Attachments Monsanto 38 and 39. Confrdential information is provided subject to
protection under IDAPA 31.01.01.067 and 31.01 .01.233, the Idaho Public Utilities
Commission's Rules of Procedure No. 67 - Information Exempt from Public Review, and
further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone]
Sincerely,
-1s/-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Edward JeweIVIPUC [e-mail] (CXW)
Ronald L. Williams/PIIC [e-mail] (C)
Brad Mullins/PIIC [e-mail]
Jim Duke/PIIC [e-mail]
Kyle Williams/PIIC [e-mail]
Val Steiner/PIIC [e-mail]
Brian Collins/Monsanto [e-mail]
Maurice Brubaker/IVlonsanto [e-mail] (C)
Jim R. Smith/Monsanto i im.smithl @baver.com (C)
Brian Andrews/Ivlonsanto bandrews@consultbai. com (C)
Ben Otto/ICL [e-mail] (C)
Eric Olsen/IIPA [e-mail] (C)
Dr. Lance Kaufuao/IIPA [e-mail] (C)
Anthony YankeUIIPA [e-mail] (C)
Matthew Gerhart/Sierra Club matt.eerhaxt@.sierraclub.ore
Ana Boyd/Sierra Club [e-mail]
PAC-E-18-08 / Rocky Mountain Power
September 30,2020
Monsanto 3d Set Data Request 35
Monsanto Data Request 35
Please provide all work papers in complete electonic fonnal with all formulas
and links intact, which support PacifiCorp's Phase [I comments, including all
attachments, filed on August 28,2020.
Response to Monsanto Data Request 35
The supporting work papers for Confidential Attachment No. I are the Kiewit
Thermal Power Plant Demolition Estimates provided to parties on January 17,
2020 andMarch 16,2020. Please refer to Attachment Monsanto 35 which
provides the work paper for Attachment No. II.
Recordholder: Ted Weston
Sponsor: To Be Determined
PAC-E-18-08 / Rocky Mountain Power
September 30,2020
Monsanto 3d Set Data Request 36
Monsanto Data Request 36
Please refer to paragraph 25 of PacifiCorp's Phase I[ comments filed on August
28,2020. Please explain if the $2.3 million requested for incremental
decommissioning costs collected through rates will also be accounted for in the
accumulated depreciation accounts, thus providing a rate base offset.
Response to Monsanto Data Request 36
As stated in Paragraph 25 of the PacifiCorp Phase II comments filed August 28,
2020,"The decommissioning costs collected in rates would be deferred to a
regulatory liability account..." The regulatory liability balance would be included
in rate base, thus providing a rate base offset.
Recordholder:Nick Highsmith
Steve McDougalSponsor:
PAC-E-18-08 / Rocky Mountain Power
September 30,2020
Monsanto 3d Set Data Request 37
Monsanto Data Request 37
Please refer to paragraph 25 of PacifiCorp's Phase II comments filed on August
28,2020. Please explain if the $2.3 million requested for incremental
decommissioning costs collected through rates will be held in an interest-bearing
account.
Response to Monsanto Data Request 37
Please refer to the Company's response to Monsanto Data Request 36. The
amounts will be treated as a rate base offset rather than being held in an interest-
bearing account.
Recordholder:Nick Highsmith
Steve McDougalSponsor:
PAC-E-18-08 / Rocky Mountain Power
September 30,2020
Monsanto 3d Set Data Request 38
Monsanto Data Request 38
Please provide all work papers in complete elecfonic format, with all formulas
and links intact that support the cost items prepared by PacifiCorp and presented
in the Decommissioning Study reports prepared by Kiewit.
Response to Monsanto Data Request 38
Please refer to Confidential Affachment Monsanto 38 which contains the Q4 2019
Asset Retirement Obligations (AROs) and Owner's Costs provided by PacifiCorp
to Kiewit Engineering Group, Inc. PacifiCorp also provided the following
information and assumptions to Kiewit:
Owner's total costs shown in the report and spreadsheets as the Category 2
subtotal;
The value of 8.5 percent for "Owner AROs Indirects" shown below the
Category 7 subtotal;
Set the Contingency in Category 11 to 0 percent;
Materials and supply inventory balances for each generating facility as of
November, 2019, as shown in Category 2c;
The make, model, acquisition cost and book values of rolling stock shown in
Category 4i;
The type, acquisition cost and book values of rail cars shown nCategory 4j;
A website link to the publicly available site regarding PacifiCorp landfills and
Coal Cornbustion Residual (CCR) bonds:
https ://www.brkenersy. corn/ccrlppw.html
The value for General Liabilities as shown in Category 8a;
The value of Coal Mine Closure as shown in Category 8b; and
PacifiCorp's ownership Percentage in Category 13
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01 .233,the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
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PAC-E-18-08 / Rocky Mountain Power
September 30,2020
Monsanto 3d Set Data Request 38
Recordholder: Grant Laughter
Sponsor: To Be Determined
PAC-E-18-08 / Rocky Mountain Power
Sepember 30,2020
Monsanto 3d Set Data Request 39
Monsanto Data Request 39
Please provide all work papers in complete electonic format, with all formulas
and links intact that support the costs presented in the Decommissioning Study
reports prepared by Kiewit.
Response to Monsanto Data Request 39
Please refer to Confidential Attachment Monsanto 39 which provides copies of all
of the deliverables required by the scope of work and delivered by Kiewit
Engineering Group, Inc. Copies of the erosion control and site grading
requirements identified for each of the coal-fueled generating facilities are
included in Confidential Attachment Monsanto 39.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01 .01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Grant Laughter
Sponsor: To Be Determined