20180920Staff 20-49 to Avista.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03s7
IDAHO BAR NO. 7956
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Street Address for Express Mail
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
CHANGE ITS ELECTRIC AND NATURAL
GAS DEPRECIATION RATES
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, by
THURSDAY, OCTOBER 11, 2018.
This Production Request is continuing, and the Company is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3r.01.01.228.
SECOND PRODUCTION REQUEST
TO AVISTA
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CASE NO. AVU-8.18.03
AVU-G-I8-02
I SEPTEMBER 20,2018
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO.20: In the event that the Rosebud mine has inadequate or non-existent
coal supplies, please describe Avista's contingency plans for providing fuel to Colstrip. Please
identify any cost-effective alternatives for fueling the Colstrip plant and include all related
studies and planning documents.
REQUEST NO.21: Regarding alternate fuel supply options for Colstrip:
a. Can coal be shipped cost effectively to Colstrip by rail from sources other than the
Rosebud mine? Please explain why or why not.
b. At what expected delivered price of coal does Colstrip cease to be cost effective?
Please specify if the assumptions used to calculate this price are the same as those
used in the 2017 IRP. If not, please identify the changed assumptions and provide
source documentation.
c. Please provide a comparison of the expected delivered coal price from a source
other than Rosebud to the current estimated delivered price from Rosebud.
REQUEST NO. 22: If coal were delivered from a source other than Rosebud, would
improvement of rail line(s) be necessary? If yes, please provide estimates for the cost of the rail
improvements.
REQUEST NO. 23: Please provide all risk analyses and studies that Avista has
performed to examine the quantitative or qualitative risk associated with the development of
sections F & G of the Rosebud mine. If no analyses and studies have been conducted, please
explain why Avista has not examined that risk.
REQUEST NO. 24: Please provide a cost estimate for expanding into sections F & G of
the Rosebud mine.
SECOND PRODUCTION REQUEST
TO AVISTA 2 SEPTEMBER 20, 2018
REQUEST NO. 25: Given that the reliability of fuel supplies can affect Avista's ability
to serve its customers and the price of its service, does Avista monitor actions of the United
States Department of the Interior, or the actions of any other federal or state government
agencies, that would affect the permitting of Rosebud mine sections F & G?
a. If so, please provide the findings of that monitoring.
b. If not, please explain why the Company does not monitor this permitting process
or requirements.
REQUEST NO. 26: Please provide any analysis with workpapers that supports a useful
life through year 2034 for Unit 3 and year 2036 for Unit 4 at the Colstrip plant.
REQUEST NO. 27: Please provide a list of all capital additions for Colstrip Units 3 and
4 (broken out separately) that the Company will require to continue operation through their
current expected useful life (2034 and2036). Specifically for each capital addition, please
provide a detailed description of the investment, why it is needed, the cost, and any economic
justification for each item. Please ensure that your response includes capital investments for
future environmental compliance.
REQUEST NO.28: Please provide any analysis with workpapers that the Company has
completed to analyze earlier retirement dates for Units 3 8.4 other than the current planned
retirement dates.
REQUEST NO.29: For each Colstrip Unit, please provide the total "ORIGINAL
COST" values of the Colstrip plant identified in column 4 of the Gannett Fleming Depreciation
Study dated December 31,2016 and the value for each operating partner.
REQUEST NO. 30: Please provide an update explaining the current non-operational
state (non-compliance with environmental standards) of Colstrip Units 3 and 4. What are the
plans to bring the plant back into compliance and to make Units 3 &. 4 operational? Please
include:
SECOND PRODUCTION REQUEST
TO AVISTA aJ SEPTEMBER 20, 20I8
a. the cause of the shutdown;
b. any investments and capital cost amounts needed to bring the units into emissions
compliance;
c. time needed for the plant to become available for dispatch in order to provide
reliable generation;
d. impacts to operating, dispatch, and insurance costs;
e. the impact to net power costs over the expected time the plant is expected to be
down; and
f. the Company's plan for informing state regulators.
REQUEST NO. 31: Please provide a description of the circumstances, the timing, the
duration, and the total cost of all forced outages by unit at Colstrip Units 3 and 4 since 2008.
The total costs should specify repair costs, replacement power costs, and insurance costs.
REQUEST NO. 32: Does Avista include the cost of forced outages in its forecast of
cost assumptions for Colstrip Units 3 and 4? If so, please provide those cost assumptions. If not,
please explain why not.
REQUEST NO. 33: Please identify the date when Avista plans to install the enhanced
Mercury controls referenced in Avista's response to Staff Production Request No. 6.
REQUEST NO. 34: PageT-4 of Avista's 2017 IRP stated that "Title V operating permit
renewal applications are in process for [Colstrip] Units 3 and 4. ..." to comply with the Clean Air
Act regulations. Please provide an update on the status of those applications.
REQUEST NO. 35: The Billings Gazette reported on August 10,2018, that "Units I
and2 typically clear the air pollution bar test results by relying on a weighted average of
pollution test results from all four units. Results from Unit 3, when performing properly, and
Unit 1, have pulled Colstrip into compliance, according to EPA archived data. Units 2 and 4 in
past tests haven't cleared the bar without help."
SECOND PRODUCTION REQUEST
TO AVISTA 4 SEPTEMBER 20,20I8
a) Please confirm or deny that Unit 4 has difficulty passing pollution tests without
Unit 3.
b) Please provide a full explanation of either the confirmation or denial.
c) If confirmed, explain in detail how Avista plans to manage this issue for the
duration of the plant operation.
REQUEST NO.36: Please provide the current Federal Implementation Plan and State
Implementation Plan for each Colstrip Unit.
REQUEST NO. 37: Please provide the results of the Federal Implementation Plan
progress review that was performed on Colstrip Units 3 and 4 in September 2017.
REQUEST NO. 38: Please provide a description of and an update on the status of the
third-party interconnection request for Project#46:750 MW Wind at Colstrip 500 kV in
Montana proposed for September 2018.
REQUEST NO. 39: Please provide the most recent 5-year projected business plan and
capital budget for Colstrip Units 3 and 4.
REQUEST NO. 40: Staff understands that Colstrip units are overhauled every three or
four years. Please provide the planned overhaul schedule and associated costs for Units 3 and 4
from 2018 through 2036.
REQUEST NO. 41: Staff understands that Avista agreed to a2027 end-of-life date for
Colstrip Units 3 and 4 for depreciation in Washington State. Please provide all analysis that
supports 2027 as an economic end of life date for Units 3 and 4.
REQUEST NO. 42: Page l2-3 of Avista's 2017 IRP lists the resource options which the
Company considered for replacing Colstrip in the event that plant retires early.
a. Colstrip provides about 246 MW for Avista. Please explain why the tables show
566 - 571 MW resource replacement options.
SECOND PRODUCTION REQUEST
TO AVISTA 5 SEPTEMBER 20,2018
b. Please explain why this resource list does not include market purchases, power
purchase agreements, or any renewable resources as possible replacement
resources.
REQUEST NO. 43: Please explain if renewing the Lancaster Power purchase
agreement (283 MW) that expires in2026 could be used to meet load requirements previously
served by Colstrip Units 3 and 4 (246 MW) if that plant were retired in 2027 .
REQUEST NO. 44: If Colstrip continues operating, please identify the date that SCRs
would be required for compliance with state and/or federal regulations.
REQUEST NO. 45: Page l2-3 of Avista's 2017 IRP states that regarding Colstrip
retirement in 2030 or 2035 that "Reduced capital spending offsets some of the of the cost
increases prior to shutdown, but not enough to offset the increase." Please explain why the
Company did not model apre-2028 shutdown date that would let the Company avoid significant
SCR expenses.
REQUEST NO. 46: Please provide all presentations made to the Colstrip Owners
Meeting Group between June20ll and September 2018, including, but not limited to, the
"Unit 3 Overhaul Challenge Presentation" from the April 2017 meeting.
REQUEST NO. 47: Please provide a summary of the discussion on the "Colstrip
Maintenance and Contract Status," "Real Estate Resolution," and "LP Amina-Boiler Model
Preliminary Evaluation" from the June and July 2017 Colstrip Owners Meeting.
REQUEST NO. 48: Please provide a summary of the discussion of the "2 year
expenditures associated with the brine concentrator capital project" from the April2017 Colstrip
Owners meeting. In particular, please explain the need for the statement that "Going forward,
owners will be asked to commit to total project cost when the projects are multi-year."
SECOND PRODUCTION REQUEST
TO AVISTA 6 SEPTEMBER 20,2018
REQUEST NO. 49: In its 2017 IRP modeling, did Avista let PRiSM select the most
optimal retirement date for Colstrip Units 3 and 4 or did the Company hard-code the operating
life to a specific date? If the Company hard-coded the operating life, please explain how that
helps select the most cost-effective resources.
Dated at Boise,Idaho, this'Zdl9 day of September 2018.
i:umisc:prodreq/avue I 8.3_avugl 8.2bkberkrfsd prod req2
SECOND PRODUCTION REQUEST
TO AVISTA 7 SEPTEMBER 20, 2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF SEPTEMBER 2018,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, TN CASE NOS. AVU-E-18-03/
AVU-G-18.02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
PATRICK EHRBAR
SR MGR RATES & TARIFFS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
avi stadockets@ avi stacorp. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 8370I
E-mail: [e-mail]
RONALD L WILLIAMS
WTLLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-mail: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail: [e-mail]
ELECTRONIC SERVICE ONLY
LARRY CROWLEY, DIR
ENERGY STRATEGIES INST.
E-MAIL : [e-mail]
ELECTRONIC SERVICE ONLY
CAROL HAUGEN
E-MAIL:
carol. haugen@clearwaterpaper. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
TRAVIS RITCHIE
STAFF ATTORNEY
SIERRA CLUB
2IOI WEBSTER ST STE 13OO
OAKLAND CA946I2
E-mail: travis.ritchie@,sienaclub.org
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 83716
E-mail: deanjmiller@,cableone.net
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
ELECTRONIC SERVICE ONLY
MARV LEWALLEN
E.MAIL:
marv. lewallen@,clearwaterpaper.com
CERTIFICATE OF SERVICE
,4a^.(1
SECRET,{Y -