20141201Fourth Quarterly Report.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Gounsel
lnordstrom@idahooower. com
December 1,2014
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Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re:Case No. !PC-E-13-16
Selective Catalytic Reduction ("SCR') Controls on Jim Bridger Power Plant Units 3 and 4
Dear Ms. Jewell:
ln Order No. 32929, the ldaho Public Utilities Commission ("Commission") directed
ldaho Power Company ("Company") to submit quarterly reports updating the Commission
on any changes to environmenta! policy or regulations until such time as the Jim Bridger
Power Plant upgrades are installed and placed in service. The enclosed materials indicate
that the Company still expects the SCRs on Units 3 and 4 will be placed in service by
December 31,2015, and December 31,2016, respectively.
Please note that the attachment to this report is commercially sensitive and if
disclosed freely could subject ldaho Power or its customers to risk of competitive
disadvantage or other business injury. Consequently, the attachment will be provided
separately to those parties that have signed the Protective Agreement in this matter. The
undersigned attorney, in accordance with RP 233, certifies that this monthly report contains
information that is a trade secret or privileged or confidentia! as described in ldaho Code $
9-340, et seq., and $ 48-801, et seq., and as such is exempt from public inspection,
examination, or copying.
Very truly yours,
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Lisa D. Nordstrom
LDN:kkt
Enclosures
cc: Service List
RA files
Legalfiles
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
4th Quarterlv Report for the Jim Bridoer Ptant
Selective Gatalvtic Reduction Upsrade at Units 3 and 4
December 1. 2014
This quarterly report provides an update as to the current status of environmental policies or
regulations that are relevant to the construction of the Selective Catalytic Reduction ('SCR')
controls at the Jim Bridger Plant Units 3 and 4 ("Bridger Plant"), as well as a status update on
the Company's efforts toward performing a new Coal Unit Environmental lnvestment Analysis
("Coal Study"). This report also provides a construction progress update for the SCR installation
project through November 14,2014, and a schedule of major construction milestones. Finally, a
summary of actual project costs and a forecast of total project costs as of September 30, 2014,
is provided as a confidential attachment to this report.
Environmental Reou :
Clean Air Act Section 111(d) for Existinq Power Plants
On June 2,2014, the Environmental Protection Agency ('EPA') released its draft proposal to
regulate COz emissions from existing power plants. On September 16, 2014, the EPA formally
extended the period for public comment on the draft rule from October 16, 2014, to December 1,
2014.
On December 1, 2014, ldaho Power Company ("ldaho Power" or "Company") submitted
comments to the EPA on the draft rule. ln addition to the Company's individual comments,
ldaho Power worked collaboratively with a number of state agencies and industry groups to
draft comments on the draft rule that were submitted to the EPA on December 1,2014.
The final rule is expected by June 2015 with a deadline of June 2016for the states to issue their
State lmplementation Plans ('SlP'). lt is currently estimated that approval or disapproval, from
the federal EPA of the SlPs will occur in the 2016-2018 timeframe.
While the Company does not know the extent to which the rule will affect the Bridger Plant, the
Company will be modeling a variety of COz compliance scenarios in its updated Coal Study that
will assess the ongoing economics of the Bridger Plant under the pending regulation.
Mercurv and Air Toxics Standards ("MATS")
On November 25, 2014, the U.S. Supreme Court announced it will review whether the EPA
should have considered the cost of complying with the MATS when it finalized the rule in
December 2011. The U.S. Court of Appeals for the District of Columbia Circuit upheld the rule
in April 2014, but the Utility Air Regulatory Group, 21 states, and the National Mining
Association asked the high court to review it. The court will hear arguments in the case in the
spring and is likely to rule in June 2015; the MATS rule is scheduled to go into effect in April 16,
2015. Although ldaho Power's investments related to the MATS regulations were included in
the Company's Coal Study, they were not within the scope of the Bridger Plant SCR Upgrade
request filed in Case No. !PC-E-13-16.
ldaho Power's Coal :
An update to the Coal Study is in progress and will
lntegrated Resource Plan.
be included with the filing of the 2015
Proiect Cost Uodate:
As of September 30,2014, the Company decreased the total estimated amount of allowance for
funds used during construction ("AFUDC") by approximately $1.5 million to reflect ldaho
Power's actual observed AFUDC rates since the start of the SCR projects, and more accurate
timing of expected cost cash flows. The previous reports have included AFUDC based on the
preliminary estimate provided in the initialfiling (IPC-E-13-16).
Construction Progrc :
The project to install the SCR controls at the Bridger Plant is moving forward as planned and is
on schedule to meet the required completion dates. The following section provides a high level
description of the construction activities since the last quarterly report (which provided an
update through July 31 ,2014).
As part of the flue gas reinforcement project, the Alstom Electrostatic Precipitator ("ESP')
structural analysis and upgrade design drawings and report were received October 30, 2014.
The drawings and report were provided to Babcock & Wilcox (EPC Contractor) which will inform
them as they provide installation pricing to PacifiCorp and ldaho Power for the required
structural reinforcement of the ESP flue gas reinforcement.
The request for proposal for the installation of the boiler and air pre-heater reinforcement was
released on November 7, 2014. The pre-bid job site visit (walk down) to physically see the
boiler and air pre-heater is scheduled for December 2,2014.
The following are updates on projects/costs included as part of the Engineering, Procurement
and Construction contract (EPC Contract). As of October 28, 2014,96 percent of the 2,585
tons of Unit 3 steel and 16 percent of the 3,031 tons of Unit 4 steel have been erected. Steel
erection progress has slowed due to the cooler weather and upcoming holidays. The seasonal
slow-down is typical and is not expected to impact the in-service date of the SCRs. Progress is
expected to ramp-up in the spring of 2015.
One of the two Unit 4 induced draft fan rotor forgings has arrived in the United States from
China. Final fabrication and preassembly of the induced draft fan rotor will be completed in
Pennsylvania and delivered to the Bridger Plant once complete. The second forging is
scheduled to anive mid-December.
The entire Unit 3 reactor vessel has been erected and has been set in place with the exception
of the north reactor inlet hood. The north hood is scheduled to be installed in December 2014.
lnsulation of the exterior of the vessel is ongoing.
Both ammonia storage tanks were received on-site and set in place. Al! ammonia pipe rack
columns have been installed and grouted. lnstallation of ammonia piping is ongoing.
Sr.hedule:
The project remains on schedule to comply with the required completion dates with the following
major milestones remaining:
o Unit 4 SCR South Fan Foundation - Spring 2015. Unit 3 Fall Outage Start - September 5, 2015o Unit 3 Mechanical Completion - November 5, 2015o Unit 3 Compliance deadline - December 31, 2015o Unit 4 Fall Outage Start - September 3, 2016o Unit 4 Mechanical Completion - November 3, 2016o Unit 4 Compliance deadline - December 31, 2016
Conclusion:
The installation of SCR controls at the Bridger Plant remains on schedule and under budget.
Based on what is known today, the SCR investments continue to be the most cost-effective
means of ensuring that Units 3 and 4 comply with state and federal emissions regulations.
Further, the Company continues to believe that the Bridger Plant SCR investments represent
the lowest cost and least risk option for serving future customer demands.
3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1't day of December 20141 served a true and
conect copy of the within 4rH QUARTERLY REPORT FOR THE JIM BRIDGER
SELECTIVE CATALYTIC REDUCTION UPGRADE AT UNITS 3 AND 4, upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 837 2O-OO7 4
lndustrial Customers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (S3702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Snake River Alliance
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, ldaho 83701
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CERTIFICATE OF SERVICE
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
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CERTIFICATE OF SERVICE