20210901PAC to Bayer 91.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 1, 2021 Randall C. Budge/Bayer [e-mail] (C) Thomas J. Budge/Bayer [e-mail] (W)(C) Brian C. Collins/Bayer [e-mail] (W)(C)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer [e-mail] (C) Lance Kaufman/Bayer [e-mail] (C) James R. Smith/Bayer [e-mail] (C)
Mike Veile/Bayer [e-mail] Courtney Higgins/Bayer [e-mail] Milli Picharo/Bayer [e-mail] Neal Townsend/Bayer [e-mail] RE: ID PAC-E-21-07
Bayer Set 6th (81-102) Please find enclosed Rocky Mountain Power’s Response to Bayer 6th Set Data Request 91. Also provided via BOX is Confidential Attachment Bayer 91. 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. If you have any questions, please feel free to call me at [phone].

Sincerely, ____/s/____ J. Ted Weston Manager, Regulation Enclosures C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC [e-mail] Adam Gardner/PIIC [e-mail] (W) Kyle Williams/PIIC [e-mail] (W) Val Steiner/PIIC [e-mail] (W) Eric L. Olsen/IIPA [e-mail] (C) Anthony Yankel/IIPA [e-mail] (C) Ben Otto/ICL [e-mail] (C)
RECEIVED

2021 SEP 1 PM3:35
IDAHO PUBLIC
UTILITIES COMMISSION
Ronald L. Williams/PIIC [e-mail] Bradley G. Mullins/PIIC [e-mail] Adam Gardner/PIIC [e-mail] (W) Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W) Eric L. Olsen/IIPA [e-mail] (C) Anthony Yankel/IIPA [e-mail] (C)
Brad Purdy [e-mail] (C)

PAC-E-21-07 / Rocky Mountain Power September 1, 2021 Bayer Data Request 91
Bayer Data Request 91 Decommissioning Costs. Please refer to the Direct Testimony of Robert Van Engelenhoven, section VI.

(a) Please provide all work papers supporting the 2020 Decommissioning Studies. (b) Please provide the basis for all cost estimates made by PacifiCorp and used to
support the 2020 Decommissioning Studies.
(c) Please identify each line item of the study that includes costs incurred or expected to be incurred by PacifiCorp. Describe what the costs are and why they are expected to be incurred by PacifiCorp.
(d) Please identify each line item of the study that is not a legal obligation if
PacifiCorp builds replacement generation at the plant site. (e) Please identify each line item of the study that is not a legal obligation if
PacifiCorp does not build replacement generation at the plant site.
(f) Please provide the number of decommissioning studies performed by Kiewit Engineering Group Inc. of coal-fired generation plants prior to producing the 2020 Decommissioning Studies.
(g) Please provide the number of decommissioning studies performed by Kiewit
Engineering Group Inc. of electric generation plants prior to producing the 2020 Decommissioning Studies.
(h) Please provide the number of decommissioning studies performed by Kiewit
Engineering Group Inc. of rate-regulated assets prior to producing the 2020 Decommissioning Studies. Response to Bayer Data Request 91
(a) Please refer to Confidential Attachment Bayer 91 which provides copies of all
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 also provided in Confidential Attachment Bayer 91. (b) The design basis is provided in Confidential Attachment Bayer 91. (c) PacifiCorp has incurred or expects to incur all of the costs identified in the line items of the study. Estimates in the study may differ from estimates
currently included in rates and may differ from actual costs. Additionally,
PAC-E-21-07 / Rocky Mountain Power September 1, 2021 Bayer Data Request 91
actual costs may differ based on the level of project definition incorporated into scope of the Class 3 AACE estimates and future changes in market costs. Please refer to Confidential Exhibit No. 33 and Confidential Exhibit No. 34, and PacifiCorp’s response to subpart (a) above for a description of the costs
and basis for the costs.
(d) PacifiCorp does not currently anticipate building replacement generating facilities on the coal-fueled generating facility sites.

(e) All items PacifiCorp expects to incur are legal obligations or have the potential to expose PacifiCorp and PacifiCorp’s customers to legal liabilities. (f) Please refer to Confidential Attachment Bayer 91. Kiewit’s qualifications are included therein.

(g) Please refer to the Company’s response to subpart (f) above. (h) Please refer to the Company’s response to subpart (f) above.

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: Robert Van Engelenhoven