20210928PAC to Staff 175-195-Redacted.pdf

ROCKY MOUNTAIN
POWER
ii:CEiirED
-':; lr;' 23 Pli 12, l7
, . - ,.-}' 1.. ;..it _, iu:l i. i-r::_t;ilii
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 28,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.norivuki uc.idaho.sov (c)
RE ID PAC-E-2I.07
IPUC Set 7 (175-195)
Please find enclosed Rocky Mountain Power's Responses to IPUC 7h Set Data Requests 183-
185, 190, 192, and 194. The remaining response will be provided under separate cover.
Provided via BOX are the Confidential Attachments and Confidential Responses. Confidential
information is provided subject to protected under IDAPA 31.01.01.067 and 31.01.01.233, the
Idaho Public Utilities Commission's Rules of ProcedureNo. 67 - Information Exempt from
Public Review, and further subject to any subsequentNon-Disclosure Agreement (NDA)
executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Ronald L. Williams/PllC [e-mail]
Bradley G. Mullins/PIIC brmullins@mwanal),tics.com
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 Yankelfl IPA tonv@,vankel.net (C)
Randall C. Budge/Bayer randy@,racineolson.com (C)
Thomas J. Budge/Bayer ti @racineolson. conr (WXC)
Brian C. Collins/Bayer bco I I ins@con su ltbai. com (WXC)
Maurice Brubaker/Bayer m bru baker@con su ltba i. com (C)
Kevin Higgins/Bayer khiegins@,enereystrat.com (C)
Lance Kaufinan/Bayer lance@aes i sin sieht. com (C)
James R. Smith/Bayer i im. r. sm i th (@.ic loud. com (C)
Brad Purdy [e-mail] (C)
Ben Otto/lCL botto@idahoconservation. ore (C)
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 183
IPUC Data Request 183
CONFIDENTIAL - For
(a) Does the Company have insurance to cover this loss? If not, please explain
why not.
(b) If the Company has insurance for this loss, did the Company file a claim? If
not, please explain why not.
(c) Please explain why ratepayers outside the state/jurisdiction where the fire
occurred should pay for costs to repair the damaged facilities caused by the
fire.
(d) Please provide a fiansmission/distribution map showing the Company's
facilities affected by the fire. Please detail and label the damaged facilities
specific to transmission and separately distribution.
(e) Please explain whether there are any transmission line segments affected by
this fire that supply elecnicity at transmission level voltages to customers
from a single flow direction (i.e. a radial transmission line)? If so, please
explain whether the Company is seeking recovery of those costs, from
ratepayers outside of the state/jurisdiction affected by the fire.
(f) Please explain how distibution costs for the project arelwill be recovered by
the Company.
Response to IPUC Data Request 183
(a) No, utility lines are not covered under Property Insurance, this is an industry
standard.
(b) Refer to the response to (a) above.
(c) The work described in this appropriation request (APR) was to replace
damaged fiansmission facilities and distribution facilities. Transmission costs
are allocated using the system generation (SG) allocation factor per the2020
Protocol allocation methodology and are appropriate for other jurisdictions to
pay their allocated portion. Distribution costs are situs assigned to the
jurisdiction they are located in. The Company is not asking for Idatro to
include distibution costs from other jurisdictions in ldaho's rates.
(d) Please refer to Confidential Attachment IPUC 183
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 183
(e) No. The affected section of 69 kV Lne2 has a Eansmission level generation
interconnection on a radial line, but there are no customer loads supplied at
transmission level voltage. The allocation of tansmission plant costs are
allocated using the system generation (SG) allocation factor per the 2020
Protocol allocation methodology.
(0 The distibution portion of this APR was allocated situs to California and cost
recovery will occur through a Califomia rate case proceeding.
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 fuither subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Mariya Coleman / JeffKeyser / Dennis Yegorov I Craig Larsen
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC DataRequest 184
IPUC Data Request 184
CONFIDENTIAL UEST - For
(a) Does the Company have insurance to cover this loss? If not, why not please
explain.
(b) If ttre Company has insurance for this loss, did the Company file a claim? If
not, please explain why not.
(c) Please explain why ratepayers outside the state/jurisdiction where the fire
occurred should pay for costs to repair the damaged facilities caused by the
fire.
(d) Please provide a transmission/distribution map showing the Company's
facilities affected by the fire. Please detail and label the damaged facilities
specific to transmission and separately distribution.
(e) Please explain whether there are any fansmission line segments affected by
this fire that supply electicity at transmission level voltages to customers
from a single flow direction (i.e. a radial transmission line)? [f so, please
explain whether the Company is seeking recovery of those costs, from
ratepayers outside of the state/jurisdiction affected by the fire.
Response to IPUC Data Request 184
(a) No, utility lines are not covered under Property Insurance, this is an indushy
standard.
(b) Refer to the response to (a) above.
(c) The work described in this appropriation request (APR) was to replace
damaged transmission facilities and distibution facilities. Transmission costs
are allocated using the system generation (SG) allocation factor per the 2020
Protocol allocation methodology and are appropriate for other jurisdictions to
pay their allocated portion. Distribution costs are situs assigned to the
jurisdiction they are located in. The Company is not asking for Idaho to
include distribution costs from other jurisdictions in Idaho's rates
(d) Please refer to Confidential Attachment IPUC 184.
(e) No, the Company does not have tansmission level voltage customers served
in a radial configuration affected by this fire. The allocation of kansmission
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC DataRequest 184
plant costs is allocated using the system generation (SG) allocation factor per
the 2020 Protocol allocation mettrodology.
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: Mariya Coleman / JeffKeyser / Neil Jones I Craig Larsen
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 185
IPUC Data Request 1E5
ENTIAL - For
(a) Does the Company have insurance to cover this loss? If not, please explain
why not.
(b) If the Company has insurance for this loss, did the Company file a claim? If
not, please explain why not.
(c) Please explain why ratepayers outside the state/jurisdiction where the fire
occurred should pay for costs to repair the damaged facilities caused by the
fire.
(d) Please provide a fransmission/distibution map showing the Company's
facilities affected by the fire. Please detail and label the damaged facilities
specific to transmission and separately distribution.
(e) Please explain whether there are any tansmission line segments affected by
this fre ttrat supply electicity at transmission level voltages to customers
from a single flow direction (i.e. a radial transmission line)? If so, please
explain whether the Company is seeking recovery of those costs, from
ratepayers outside of the state/jurisdiction affected by the fire.
Response to IPUC Data Request 1E5
(a) No, utility lines are not covered under Properly Insurance, this is an industry
standard.
(b) Refer to the response to (a) above.
(c) The work described in this appropriation request (APR) was to replace
damaged transmission facilities and distribution facilities. Transmission costs
are allocated using the system generation (SG) allocation factor per the 2020
Protocol allocation methodology and are appropriate for other jurisdictions to
pay their allocated portion. Distibution costs are situs assigned to the
jurisdiction they are located in. The Company is not asking for ldaho to
include distribution costs from other jurisdictions in Idaho's rates
(d) Please refer to Attachment IPUC 185.
(e) No. The affected section of 69 kV Line2 has a transmission level generation
interconnection on a radial line, but there are no customer loads supplied at
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC DataRequest 185
transmission level voltage. The allocation of tansmission plant costs is
allocated using the system generation (SG) allocation factor per the 2020
Protocol allocation methodology.
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 furttrer subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Mariya Coleman / JeffKeyser / Dennis Yegorov I Craig Larsen
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 190
IPUC Data Request 190
CONT'IDENTIAL - Please
m response
any requested below cannot be provided or is not
available, please explain why and explain how the Company assured the
consfuction of the project was completed at least cost.
(a) Analysis of Need - a justification of need for the project and a cost/beneftt
analysis comparing alternatives.
(b) Project Plan:
i. Initial project scope.ii. Proposed budget.iii. Proposed schedule.
(c) Requests for proposals @FP):
i. Project requirements.ii. Specifications.iii. Short list bidder scorecard.
iv. RFP fromwinning bid.
(d) Project construction documentation including :
i. Construction contract.ii. Organizationalchart.iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s).
viii. Confiactors change order request(s).
(e) Company project completion analysis:
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or
minus five percent during a particular year please list and explain the
reason(s) for the budget amount difference.
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC DataRequest 190
Response to IPUC Data Request 190
(a) The Project was a result of a settlement with the Colorado Departnent of
Health and Environment, which included the State Implementation Plan for
Regional Haze. The fundamental basis and need for the project is to comply
with environmental regulatory requirements. Black & Veatch was
commissioned to support this effort. Please refer to Confidential Attachment
IPUC 190-l for supporting documentation.
(b) Please refer to Confidential Attachment IPUC 190-l for the project plan
documentation.
(c) Requests for proposals @FP):
Please refer to Highly Confidential Attachment IPUC 190-2. Due to the
commercially sensitive nature of this information please contact Ted Weston
at [phone] to make arrangement to review this information.
(d) Please refer to the monthly reports in Confidential Attachment IPUC 190-3
(e) Please refer to Confidential Attachment IPUC 1904.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, 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: Mike Johanson
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 192
IPUC Data Request 192
documentation for
m response
any requested below cannot be provided or is not
available, please explain why and explain how the Company assured the
consffuction of the project was completed at least cost.
(a) Analysis of Need - a justification of need for the project and a cost/benefit
analysis comparing alternatives.
(b) Project Plan:
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
(c) Requests for proposals (RFP)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
(d) Project constuction documentation including:
i. Construction contract.ii. Organizational chart.
iii. Scope document.
iv. Work breakdown stucture.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s).
viii. Contactors change order request(s).
(e) Company project completion analysis:
i. Lessons leamed.ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus
five percent during a particular year please list and explain the reason(s)
for the budget amount difference.
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 192
Response to IPUC Data Request 192
Joint ownership in Hayden Unit 2 is governed by a Participation Agreement (the
Hayden Participation Agreement). The Hayden Participation Agreement mandates
the installation of capital improvements that are required by applicable law. The
Hayden Participation Agreement also places an independent obligation on the
Public Service Company of Colorado (PSCo or Xcel Energy), as operating agent,
to operate Hayden Unit 2 in accordance with applicable laws. Based on the
foregoing clarification, the Company responds as follows:
(a) Pursuant to Decision Cl0-1328 and Decision Cl l-0121 in Docket l0M-245E,
issued on December 15, 2010 and February 3,2011 respectively, the Colorado
Public Utilities Commission (PUC of Colorado) approved a plan of unit
retirements and replacements to the yex 2017 to implement House Bill (HB)
10-1365, the Clean Air Clean Jobs Act (CACJA). The final plan approved by
the PUC of Colorado included, among other actions, the installation of
selective catalytic reduction (SCR) conftols at Hayden Unit I by 2015, and at
Hayden Unit 2 by 2016. [n Decision Cl0-1328, the PUC of Colorado
determined "installation of SCR controls at Hayden I by 2015 is necessary
and in the public interest for emission reduction purposes."l As discussed in
paragraphs 124-128 of Decision Cl0-1328 in Docket l0M-245E, Hayden Unit
I and Hayden Unit 2 were included in the Company's proposed scenario
contingent upon the outcome of the Air Quality Control Commission's
(AQCC) regional haze Best Available Retrofit Technology (BART)
determinations for those units. The Colorado Department of Public Health and
Environment (CDPHE) reported that the AQCC made a preliminary final
determination on November 19, 2010 that BART for Hayden Station is SCR
for nifrogen oxide (NOx) reduction. The AQCC adopted a BART equivalent
emissions rate for the regionalhaze State lmplementation Plan (SIP). In light
of the AQCC's BART determination, the PUC of Colorado found that SCR
confrols on Hayden Unit I and Hayden Unit2 were needed and in the public
interest for emission reduction purposes. The PUC of Colorado further found
that including the emission control projects at Hayden in the CACJA plan
allowed for "a coordinated approach for emission reduction to be adopted on a
cost-effective basis as contemplated by House Bill l0-1365."2
By Decision Cl5-0292 in Dockets I4AL-0660E & l4A-0680E, the PUC of
Colorado approved a Settlement Agreement that included approval of a
CACJA Rider to provide for current recovery of eligible CACJA projects,
including the SCR equipment at Hayden.3 The PUC of Colorado found the
CACJA Rider will allow PSCo to recover the significant costs the Company
incurred to implement its approved emission reduction plan and found the
I See ordering't[E of Decision Cl0-1328 in PUC of Colorado, Docket l0M-245F.2 Seell2S of Decision Cl0-132E in PUC of Colorado, Docket l0M-2458.
3 See \29 of Decision Cl5-0292 in PUC of Colorado, Dockets I4AL-0660E & 14A-06808.
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 192
associated rate changes "reasonable and in the public interest particularly
given the benefits of the CACJA investments."4
Cost / Benefit Analvsis - As discussed above, the PUC of Colorado approved
the installation of SCR contols on Hayden Unit I and Hayden Unit 2 to meet
emission reduction requirements. The PUC of Colorado found that including
the emission control projects at Hayden allowed for a coordinated approach
for emission reduction to be adopted on a cost-effective basis as contemplated
by FIB l0-1365.
(b) Please refer to the Company's responses to subparts (i) through (iii) below:
i. The initial project scope involved reftofitting Hayden Unit I and Hayden
Unit 2 with SCR contols to meet lower NOx emission limits at the plant.
The project also involved installation of an anhydrous ammonia storage
and forwarding system to supply both SCRs, and modifications to the
Hayden Unit I Induced Draft Fan (ID Fan) motors.
ii. The initial total estimated cost for the Hayden Unit I SCR was $73.9
million. The cost estimate was subsequently adjusted to $74.8 million
when it was determined that upgrades to the existing ID Fans were
required, including fan tipping and upgraded motors.
iii. The SCR installation for Hayden Unit I was proposed to be completed by
December 2015.
(c) Please refer to the Company's responses to subparts (i) through (iv) below:
i. Please refer to Confidential Attachment IPUC 192-l which provides a
copy of the request for proposals (RFP) document.
Please refer to Confidential Auachment IPUC 192-l which provides a
copy of the RFP document.
iii. Please refer to the statement at the beginning of this response concerning
the Hayden Participation Agreement. PacifiCorp does not possess the
requested records, Xcel Energy as plant operator has control over these
records.
iv. Please refer to the statement at the beginning of this response concerning
the Hayden Participation Agteement. PacifiCorp does not possess the
requested records, Xcel Energy as plant operator has contol over these
records.
4 See f17l of Decision Cl5-0292 in PUC of Colorado, Dockets I4AL-0660E & l4A-0680E
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 192
(d) Please refer to the Company's responses to subparts (i) through (viii) below:
i. Please refer to the statement at the beginning of this response conceming
the Hayden Participation Agreement. PacifiCorp does not possess the
requested records, Xcel Energy as plant operator has control over these
records.
Please refer to the statement at the beginning of this response concerning
the Hayden Participation Agreement. PacifiCorp does not possess the
requested records, Xcel Energy as plant operator has control over these
records.
iii. Please refer to Confidential Attachment IPUC 192-l which provides a
copy of the RFP document.
iv. Please refer to the statement at the beginning of this response conceming
the Hayden Participation Agreement. PacifiCorp does not possess the
requested records, Xcel Energy as plant operator has control over these
records.
v. Please refer to Confidential Attachment IPUC 192-2which provides
copies of the semi-annual progress reports filed with the PUC of Colorado.
vi. Please refer to Confidential Attachment IPUC 192-2. PSCo filed l0
informational semi-annual progress reports for the Hayden Emissions
Control Project in PUC of Colorado Docket I lA-917E over the course of
construction of the project. The semi-annual progress reports included a
summary of overall project status, status of contracts, project financial
performance, and projected versus actual construction schedule. The semi-
annual progress reports were filed on the following dates:
o September I8,2012 (Corrected)o March 15,2013o September 20,2013o March 17,2014o September 25,2014. April 6,2015o September 25,2015. April 8, 2016
o October 5,2016o April 20,2017 (Final Report)
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC Data Request 192
vii. Please refer to the statement at the beginning of this response concerning
the Hayden Participation Agreement. PacifiCorp does not possess the
requested records, Xcel Energy as plant operator has control over these
records.
vill Please refer to the statement at the beginning of this response concerning
the Hayden Participation Agreement. PacifiCorp does not possess the
requested records, Xcel Energy as plant operator has control over these
records.
(e) Please refer to the Company's responses to subparts (i) through (iv) below:
i. A project complete analysis was not performed following the SCR
installation. As shown in the final semi-annual progress report dated April
20,2017, the Hayden Unit I SCR project was completed on schedule and
under budget.
ii. Please refer to Confidential Attachment IPUC 192-2which provides
copies of the filed semi-annual progress reports filed with the PUC of
Colorado.
iii. Please refer to Confidential Attachment IPUC 192-2which provides
copies of the filed semi-annual progress reports filed with the PUC of
Colorado.
iv. Please refer to Confidential Attachment IPUC 192-2which provides
copies of the filed semi-annual progress reports filed with the PUC of
Colorado for budget estimates compared to actuals over the course of
project construction.
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: All provided by Hayden directly (Xcel Energy / PSCo)
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power
September 28,2021
IPUC DataRequest 194
IPUC Data Request 194
CONFIDENTIAL - Please documentation for
response to
any requested below cannot be
provided or is not available, please explain why and explain how the Company
assured the construction of the project was completed at least cost.
(a) Analysis of Need - a justification of need for the project and a cost/benefit
analysis comparing alternatives.
(b) Project Plan
i. Initial project scope.ii. Proposed budget.
iii. Proposed schedule.
(c) Requests for proposals (RFP)
i. Project requirements.
ii. Specifications.iii. Short list bidder scorecard.
iv. RFP from winning bid.
(d) Project construction documentation including
i. Construction contract.ii. Organizational chart.
iii. Scope document.
iv. Work breakdown sffucture.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s).
viii. Contactors change order request(s).
(e) Company project completion analysis:
i. Lessons learned.ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or
minus five percent during a particular year please list and explain the
reason(s) for the budget amount difference.
PAC-E-21-07 / Rocky Mountain P,ower
Septenrber 28,2021
IPUC Data Request 194
Response to IPUC DataRequest 194
Please refer to Highly Confidential Attachment IPUC 194. Due to the
commercially sensitive nafire of this inforrration please contact Ted Weston at
(80D22A-2963 to make amngementto review this information.
Recordholder: Todd Jensen
Sponsor: To Be Determined