20211013PAC to Bayer 233-240-Redacted.pdf

ROCKY MOUNTAIN
POWER
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October 13,2021
Randall C. Budge/Bayer randv @rac ineolson. com (C)
Thomas J. Budge/Bayer [e-mail] (WXC)
Brian C. Collins/Bayer bcol I ins@con su I tbai. com (WXC)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer khi s g in s@enerqystrat. com (C)
Lance Kaufman/Bayer I an ce@,aeq i sin si sht. com (C)
James R. Smith/Bayer j im. r. sm i th @ic loud. com (C)
Mike Veile lBayer m ike. vei [e-mail]
Courtney Higgins/Bayer [e-mail]. com
Milli Picharo lBay er [e-mail]
Neal Townsend/Bayer [e-mail]
RE:ID PAC.E.2I-07
Bayer Set l6h (233-240)
Please find enclosed Rocky Mountain Power's Responses to Bayer 16tr Set Data Requests 233-
240. Also provided via e-mail is non-confidential Attachment Bayer 233. Provided via
encryption and BOX is Confidential Attachment Bayer 235 and Confidential Responses Bayer
235-236. Confidential information is provided subject to protection under IDAPA 31.01.01.067
and 3l .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.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Ronald L. Williams/PIIC ron@wil I iamsbradbury.com
Bradley G. Mullins/PIIC brmu I I ins@,mwanalyt ics. com
Adam Gardner/PIIC AGardner(@idahoan. com
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. steiner@. itafos. com (W)
(w)
Eric L. Olsen/IIPA elo@echohawkcom (C)
Anthony Yankel/ItrA tonv@.vankel.net (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PtrC [e-mail]
Adam Crardner/PtrC [e-mail] (W)
Kyle trtilliams/PtrC [e-mail] (W)
Val Steincr/PtrC [e-mail] (W)
Eric L. Ols€m/IIPA elo@.e,chohawkcom (C)
Anthony Yankel/IIPA [e-mail] (C)
Bmd Purdy [e-mail] (C)
PAC-E-2147 / Rocky Mountain Pou,er
October 13,2021
Bayer Data Request 233
Bayer Data Request 233
Please provide RMP's Response to UAE Data Request 3.9 in Utah Public Service
Commission DocketNo. 20{35{4, including all supplemental rresponses and
atlachments.
Rcsponse to BeyerData Request233
Please refer to Attachment Bayer 233.
Recordtrolder: Dan Martinez
Sponsor;To Be Determined
PAC-E-21-07 / Rocky Mountain Power
October 13,2021
Bayer Data Request234
Bayer Data Request 234
Please refer to the RMP response to Bayer DR 91, confidential attachments*CONF - PacifiCoqp TPP Colsfrip 3 &.4 Demolition Estimates 03.8.2C20
FINAL Rev0.xlsx" and "CONF - PacifiCorp TPP Colsfip3 & 4 Demolition
Estimates 03j3.2020 FINAL RevO.xlsx".
(a) Please provide the basis and all supporting documentation for the
Response to Bayer Data Request 234
Due to the incomplete sentence in this data request, PacifiCorp is unable to
provide a response.
Recordholder:Not applicable
Not applicableSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 13,2021
Bayer Data Request235
Bayer Data Request 235
CONFIDENTIAL REQUEST - Please refer to the RMP response to Bayer DR
9l, confidential attachments "CONF- PacifiCorp TPP Demolition Colstrip
Estimate - 03-13-2020 Final Report Rev. 0.pdf' and "CONF- PacifiCorp TPP
Demolition Estimates - 0l-15-2020 Final Report Rev. l.pdf'.
(a) Page 7 of "CONF- PacifiCorp TPP Demolition Estimate - 03-l
lities, and
Owner's costs to plan and oversee. Please provide such data for each plant in
the referenced attachments.
(b) Page 39 of
2020Final
rate
(c) Page 18 of
2020 Final
"CONF- PacifiCorp
"CONF- PacifiCorp
Rev.states
supportmg documentation.
TPP Demolition Estimate - 03-13-
Rev.' states
l5 of "CONF- PacifrCorp TPP Demolition Estimate - 03-13-
Rev.0 states
TPP Demolition Estimate - 03-13-
are
not
(d) Page
2020
ls an
to any known authorities
supporting such depth
(e) Please explain how PacifiCorp intends to recover in rates costs related to
"Other Items to Consider".
Response to Bayer Data Request 235
PAC-E-21-07 / Rocky Mountain Power
October 13,2021
Bayer Data Request235
(a) PacifiCorp objects to this data request to the extent that it seeks materials
subject to attorney-client or other privilege. Without waiving this objection,
PacifiCorp responds as follows:
Please refer to Confidential Attachment Bayer 235 which provides the Asset
Retirement Obligations (ARO) source and estimates. Note: the 2019 values
were not used in the study because the study was in Q4 2019 dollars. Kiewit
also generated its own estimate of asbestos costs, which are contained in the
demolition study.
(b) An approximate average of the owner's costs as a percentage of the direct
project costs was obtained from ARO projects that had been recently
completed at the time the Thermal Power Plant Demolition Estimates were
being performed.
(c) Removal of rail described in Section 3.1 Colstrip 3 & 4 Assumptions, Item 18.
Rail: paragraph c. on page 12 (Adobe Acrobat page 18) serve Units 3 and 4
only and does not serve Units I and2. Costs for rail removal were allocated in
accordance with the first paragraph of Section 1.2 Demolition Cost Estimates
Summary and Section 3.1 Colstrip 3 & 4 Assumption, ltem 24 Common
areas.
(d) Removing structures to three feet below grade is a common practice for power
plant demolition. Specifically, NADC indicated that over 50 percent of power
plant jobs it bids have this requirement. Kiewit and NADC chose this figure
based on their extensive experience in the power plant demolition industry. It
is important to understand that the foundation material removed to three feet
below the surface is used as part of fill material and this is part of the
calculated balance of cut and fill quantities. Using these materials as fill is far
less expensive than having to truck fill material from one location to another.
(e) Please refer to the Company's response to Bayer Data Request} D.
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:Grant Laughter
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 13,2021
Bayer Data Request236
Bayer Data Request 236
CONFIDENTIAL REQLIEST - Please refer to the RMP response to Bayer DR
confi dential attachment " 20032434-CG-00 I -Hunter CONF
hatched area with label
do
assume a
entrre within the
YES,area is assumed for excavation and removal?
Confidential Response to Bayer Data Request 236
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:Grant Laughter
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 13,2021
Bayer Data Requestz3T
Bayer Data Request237
Please refer to the RMP response to Bayer DR 91, confidential attachment
"20032434-CS-701 CONF.pdf'. For each distinct pile describe the function and
operations of the pile, including whether and how the piles are utilized by each of
the four units.
Response to Bayer Data Request23T
Regarding "20032434-CS-701 CONF.pdf', the coalpiles "COAL PILE" and
"COAL PILE2* store coal for and provide for delivery of coal to Colstip Unit 3
and Colsfrip Unit 4. The coal piles "UNITS I & 2COAL PILE" store coal for and
provide for delivery of coal to Colstip Unit I and Colstip Unit 2. Coal piles are
not shared between Colstip Unit I and Colstrip UnitZ, and Colstrip Unit 3 and
Colstrip Unit 4. Coal is stored at Colstrip to prevent unit outages or reductions in
capacity due to delays in delivery of coal.
Recordholder:Grant Laughter
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 13,2021
Bayer Data Request 238
Bayer Data Request 238
Please refer to the PacifiCorp 2021 IRP page 15 which indicates Jim Bridger
Units I and 2 will convert to natural gas peakers rrl.2024.
(a) What is the end of life assumed for the converted natural gas peakers?
(b) Does RMP expect to incur any Jim Bridger related costs in *CONF-
PacifiCorp TPP Demolition Estimates - 01-15-2020 Final Report Rev. l.pdf'
prior to ttre retirement of all four units? If yes, please identiS such costs.
Response to Bayer Data Request 23E
(a) PacifiCorp objects to this request as overly broad and unduly burdensome as
any costs associated wittr future Jim Bridger Unit I and Jim Bridger Unit 2
conversion to natural gas are outside of the test year and not included in this
proceeding. Without waiving this objection, PacifiCorp responds as follows:
PacifiCorp's2021 Integrated Resource Plan (IRP), Volume I, Chapter I
@xecutive Summary), section "Preferred Portfolio Highlights", subsection
"Coal and Gas Retirements/Gas Conversions", page 15, last paragraph in this
section states:
"In addition to the coal unit retirements outlined above, the
prefened portfolio reflects 1,554 MW natural gas retirements
through 2040. This includes Naughton Unit 3 at the end of 2029,
Gadsby at the end of 2032, Hermiston at the end of 2036, and Jim
Bridger Units I and 2 atthe end of2037".
Please also refer to the 2021 IRP, Volume II, Appendix I (Capacity Expansion
Results), page 179. The retirement of Jim Bridger Unit I and Jim Bridger Unit
2 are included in the "Retirement Assumptions" table.
PacifiCorp's 2021 IRP is publicly available and can be accessed by utilizing
the following website link:
Intesrated Resource Plan (pacificorp.com)
(b) PacifiCorp objects to this request as overly broad and unduly burdensome to
the extent that it requests costs not included in this proceeding. Without
waiving this objection, PacifiCorp responds as follows:
PacifiCorp has incurred and will continue to incur costs identified for Jim
Bridger in the Thermal Power Plant Demolition Estimates prior to the
retirement of all four generating units. The scope ofwork for the study did not
PAC-E-21{7 / Roclry Mountain Power
Oetober l3,2AZl
Bayer DataRequest 238
include identifring costs that will be incurred prior to retirement of all four
generating units.
Recordholder:Grant Laughter
Rick LinkSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 13,2021
Bayer Data Request 239
Bayer Data Rqnest 239
Please refer to the PacifiCorp 2021IRP page l5 which identifies a retirement date
of Colstrip for2A25.
(a) Can PacifiCorp unilaterally close Colstrip units 3 and 4?
(b) Have the owners of Colsfrip voted to close Colsfiip trl.Z0252
Response to Bayer Deta Request 239
(a) No.
(b) No.
Recordholder: Mike Johanson
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
October 13,2021
Bayer Data Request240
BayerData Request240
Please explain how PacifiCorp intends to recover costs related to "Other Items to
Considet''.
Response to BayerData Roquest240
The costs related to "Other Items to Consider" will be recovered through a
combination of existing mechanisms and revenue requirement updates to rates
through general mte cases (GRC), updates reflected in new depreciation sf,rdies,
and as plants are retired and these costs become measurable.
Recordholder:Craig Larsen
Steve McDougalSponsor: