HomeMy WebLinkAbout20220228Barretto Direct.pdf
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
DETERMINATION VALIDATING THE
NORTH VALMY POWER PLANT BALANCING
ACCOUNT TRUE-UP.
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CASE NO. IPC-E-22-05
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
LINDSAY BARRETTO
BARRETTO, DI 1
Idaho Power Company
Q. Please state your name and business address. 1
A. My name is Lindsay Barretto. My business 2
address is 1221 West Idaho Street, Boise, Idaho 83702. 3
Q. By whom are you employed and in what capacity? 4
A. I am employed by Idaho Power Company (“Idaho 5
Power” or “Company”) as the 500 kilovolt (“kV”) and Joint 6
Projects Senior Manager. 7
Q. Please describe your educational background. 8
A. I received a Bachelor of Science degree in 9
Civil Engineering from Purdue University, West Lafayette, 10
Indiana in 2005. In 2007, I earned a Master of Science 11
degree in Civil Engineering from Purdue University. I am a 12
registered professional engineer in the state of Idaho. 13
Q. Please describe your work experience with 14
Idaho Power. 15
A. I began my employment with Idaho Power in 2010 16
as an engineer in Power Production’s Civil Engineering 17
department. As an engineer I worked on hydroelectric and 18
hatchery projects and regulatory compliance. In 2015, I 19
moved to Transmission and Distribution Engineering and 20
Construction as a project manager leading power line and 21
substation projects. In 2018, I became an Engineering 22
Leader, responsible for the Stations Engineering and Design 23
department. In 2020, I was promoted to my current 24
position, Senior Manager of 500kV and Joint Projects, where 25
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Idaho Power Company
my responsibilities include supervision over Idaho Power’s 1
jointly-owned coal assets. 2
Q. What is the purpose of your testimony in this 3
proceeding? 4
A. The purpose of my testimony is to discuss the 5
prudence of investments made at the North Valmy Power Plant 6
(“Valmy”) that have been added to the associated plant 7
balances since the Company’s last request to update Valmy 8
plant balances became effective on June 1, 2019, Case No. 9
IPC-E-19-08, and to inform the Idaho Public Utilities 10
Commission (“Commission”) of necessary future investments 11
at the plant to ensure Unit 2 continues to be available for 12
reliable load service through the end of 2025. 13
Q. Have you prepared any exhibits detailing the 14
investments made at Valmy since the last update to rates? 15
A. Yes. In Case No. IPC-E-19-08, the Commission 16
approved, with Order No. 34349, Valmy investments through 17
December 31, 2018. Therefore, Exhibit No. 2 details Idaho 18
Power’s share of the investments made at Valmy between 19
January 1, 2019, and December 31, 2021. Projects for which 20
the Company’s ownership share is over $20,000, and all 21
investments associated with Unit 1, include a project 22
description and investment purpose classification for 23
environmental compliance, safety, or for reliability. 24
Confidential Exhibit No. 3 presents the forecasted capital 25
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Idaho Power Company
expenditures for the 2022 through 2025 time period. 1
I. THE VALMY PLANT 2
Q. Please describe the Valmy plant. 3
A. Valmy is a coal-fired power plant that 4
consists of two units and is located near Winnemucca, 5
Nevada. Unit 1 went into service in 1981 and Unit 2 6
followed in 1985. Idaho Power owns 50 percent of Valmy. NV 7
Energy is the co-owner of the plant with the remaining 50 8
percent ownership and operates the Valmy facility. Idaho 9
Power and NV Energy (collectively, the “Parties”) work 10
jointly to make decisions regarding Valmy. The plant is 11
connected via a single 345 kilovolt transmission line to 12
the Idaho Power control area at the Midpoint substation. 13
Idaho Power owns the northbound capacity and NV Energy owns 14
the southbound capacity of this line. The Company exited 15
coal-fired operations of Unit 1 December 31, 2019, as 16
accepted1 by the Commission as part of Idaho Power’s 2017 17
Integrated Resource Plan. 18
Coal for Valmy is shipped via railroad from various 19
mines in Utah, Wyoming, and Colorado. The power plant uses 20
a variety of emissions control technologies, including 21
state-of-the-art fabric filters that remove more than 99 22
percent of particulate emissions. A dry sorbent injection 23
system was installed in Unit 1 to reduce acid gas emissions 24
1 Order No. 33983.
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Idaho Power Company
and flue-gas scrubber technology is utilized on Unit 2 for 1
the reduction of sulfur dioxide emissions. 2
Q. Please describe the current agreements under 3
which the Co-Owners own and operate Valmy. 4
A. The ownership and operation of Valmy is 5
governed by three agreements: the Agreement for the 6
Ownership of the North Valmy Power Plant Project, the 7
Agreement for the Operation of the North Valmy Power Plant 8
Project, both of which are dated December 12, 1978, and the 9
North Valmy Station Operating Procedures Criteria, dated as 10
of February 11, 1993, between Idaho Power Company and 11
Sierra Pacific Power Company,2 as amended by Amendment No. 1 12
to the Operating Procedure Criteria for Valmy Coal 13
Diversion Procedures and Usage, dated as of January 1, 2012 14
(collectively, the “Existing North Valmy Agreements”). 15
Additionally, the Parties entered into the North Valmy 16
Project Framework Agreement between NV Energy and Idaho 17
Power dated as of February 22, 2019 (“Framework 18
Agreement”), memorializing the terms and conditions under 19
which either partner may elect exit of participation of 20
Valmy. 21
Q. What is the position of Valmy Unit 2 in Idaho 22
Power’s generation portfolio as identified in the 2021 IRP? 23
2 Sierra Pacific Power Company has conducted business as NV
Energy since 2008.
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Idaho Power Company
A. The Preferred Portfolio identified in the 2021 1
IRP, filed in Case No. IPC-E-21-43, includes an exit from 2
Valmy Unit 2 in 2025, concluding that the 2025 exit from 3
Valmy provides a more favorable economic outcome when 4
compared to an earlier exit. 5
II. VALMY CAPITAL BUDGET PARTICIPATION 6
Q. As a 50-percent owner in the plant, is Idaho 7
Power involved in the decision-making process related to 8
capital investments at Valmy? 9
A. Yes. As the plant operator, NV Energy 10
manages the capital budget for Valmy. However, Idaho Power 11
has established guidelines at Valmy to allow NV Energy to 12
manage the capital budget as needed and directed by the 13
plant manager, without exceeding the yearly budget, or 14
adding large projects without authorization by the Parties. 15
These guidelines provide the appropriate level of oversight 16
while allowing the plant operator to practically manage the 17
plant and any variances that may occur throughout the 18
budget year. 19
Q. What guidelines are in place to monitor 20
capital expenditures at Valmy? 21
A. First, if Idaho Power’s share of the capital 22
forecast is greater than the capital budget by more than 23
$100,000, the Company will review and may authorize the 24
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Idaho Power Company
budget change. In addition, all new or unbudgeted Unit 2 1
or common facility capital projects larger than $1,000,000, 2
at the plant level, require a review and authorization in 3
writing prior to starting the project. Finally, any time 4
an individual Unit 2 or common facility capital project 5
with a value greater than $1 million, at the plant level, 6
is expected to exceed the current year original budget by 7
20 percent, Idaho Power will review and authorize it in 8
writing prior to starting or continuing. 9
Q. Aside from the guidelines, are there any 10
other ways the Company participates in the capital budget 11
process? 12
A. Yes. Individual capital project variances 13
are discussed between the Parties during Ownership Meetings 14
and other meetings as directed by the Parties. In 15
addition, NV Energy produces an Authorization for 16
Expenditures (“AFE”) request for all capital projects. 17
AFEs include the project title, date, project manager, 18
description and purpose of the expenditure, cost and budget 19
information, along with various other information to 20
provide support for the project. If the project is 21
expected to exceed the AFE amount by either 10 percent or 22
$100,000, a supplemental AFE is required. Currently, Idaho 23
Power provides authorization to NV Energy of all AFEs and 24
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Idaho Power Company
supplemental AFEs for each project. Idaho Power has 1
requested that no projects begin, and the budget may not be 2
exceeded, unless the AFE is approved by both NV Energy and 3
Idaho Power. Lastly, in addition to the plant-specific 4
guidelines detailed above, Idaho Power performs holistic 5
budget reviews on a monthly and quarterly basis. This 6
includes capital expenditures at all of the Company’s 7
facilities, including Valmy, and therefore provides an 8
additional review process through which the Company 9
monitors its capital spend at Valmy. 10
III. VALMY INVESTMENTS SINCE 2018 11
Q. What is the time period for which Idaho Power 12
is requesting a prudence review of Valmy investments for 13
purposes of validating the Valmy balancing account true-up? 14
A. Idaho Power’s last request to update Valmy 15
plant balances, Case No. IPC-E-19-08, became effective on 16
June 1, 2019, and included actual Valmy plant balances 17
through December 31, 2018. Therefore, the Company is 18
requesting a prudence determination on incremental Valmy 19
investments since the last Valmy rate update, or those 20
investments made at the plant during the January 1, 2019, 21
through December 31, 2021, time period. There have been a 22
number of investments required to operate the plant in a 23
safe, efficient, and reliable manner, including investments 24
required to ensure environmental compliance as well as a 25
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Idaho Power Company
number of investments for routine asset replacement. 1
Q. Have you identified the investments made at 2
Valmy during the January 1, 2019, through December 31, 3
2021, time period? 4
A. Yes. Exhibit No. 2 presents Idaho Power’s 5
share of the investments made at Valmy between January 1, 6
2019, and December 31, 2021, detailing 57 different 7
projects totaling $4.66 million. In addition, for those 8
projects for which Idaho Power’s ownership share is over 9
$20,000, and all investments associated with Unit 1, the 10
Company has included a project description and investment 11
purpose classification as to whether the investment was for 12
environmental compliance, safety, and/or reliability. Of 13
the 40 projects for which a detailed project description 14
and investment purpose classification was provided, 23 were 15
for continued reliable plant operations, four were required 16
for environmental compliance, one was for the safe 17
operations of the plant, and 12 were for a combination of 18
either reliability, environmental compliance, or safety. 19
Q. Why did the Company include a project 20
description and investment purpose classification for all 21
investments associated with Unit 1, even if they were less 22
than $20,000? 23
A. Idaho Power included a project description and 24
investment purpose classification for all investments 25
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Idaho Power Company
associated with Unit 1 to highlight that although the 1
Company exited operations of Unit 1 on December 31, 2019, 2
there were investments required to ensure reliable 3
operations of Unit 1 until the Company’s exited 4
participation in coal-fired operations. 5
Q. Were all the projects comprising the $4.66 6
million in investments that occurred between January 1, 7
2019, and December 31, 2021, necessary for either 8
environmental compliance, the safe and economic operation 9
of the plant, or for reliability purposes? 10
A. Yes. 11
Plant Reliability Investments 12
Q. You indicated there were 23 investments 13
greater than $20,000 required for the reliable operation of 14
the plant. What was the largest investment made to maintain 15
reliability? 16
A. While not the largest investment made during 17
the January 1, 2019, through December 31, 2021, time 18
period, the largest investment made solely for reliability 19
purposes was made in 2019 for approximately $540,000 when 20
freeze protection heaters were installed at the plant. 21
Q. What necessitated installation of freeze 22
protection heaters? 23
A. When the Valmy operating schedule shifted to 24
running the units in only the summer months and to be in 25
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Idaho Power Company
long-term layup during the remaining months of the year, it 1
was determined that with both units offline there was no 2
auxiliary steam to provide heat to the turbines, boilers 3
and buildings to keep them dry and above the dew point, per 4
the long-term layup plan. 5
Q. How was Valmy heated at the time? 6
A. The plant was renting portable electric space 7
heaters to sufficiently heat the plant buildings and 8
equipment during the layup period. However, it was 9
determined that the purchase of the heaters was more cost-10
effective than renting. In addition, the purchase and 11
installation included four water-to-air dry finned coolers 12
which cool the component cooling system on each unit and 13
exhaust warm dry air into the lower level of the turbine 14
building, reducing the number of electric heaters required 15
to be purchased. Heating of the turbines and buildings 16
helps ensure the units can be operational when needed. 17
Q. What additional investments were made at Valmy 18
to maintain reliability? 19
A. The next set of investments made to maintain 20
reliable operations of Valmy were associated with normal 21
wear and tear of existing investments. First, for 22
approximately $225,000, the Unit 2 pin mixer, which unloads 23
the wet fly ash, required replacement and was rebuilt prior 24
to the summer run to avoid the potential of a serious 25
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Idaho Power Company
failure due to the lack of non-redundant equipment. In 1
addition, approximately $107,000 was spent to replace 2
bushing gaskets and for the regasketing of the bushing 3
terminal plant. Finally, the Unit 2 pulverizers required a 4
major rebuild, as expected every 18 to 24 months, for 5
approximately $166,000. 6
Q. Why must bushing gaskets be replaced? 7
A. The terminal plate gaskets for the high 8
voltage bushings of the generator were worn out and there 9
was indication of bushing gaskets leaking as the viscasil 10
was seeping through the bushing gaskets. Bushing gasket 11
leakage could lead to catastrophic failure of the 12
generator. 13
Q. When was this issue first identified? 14
A. The issue was first identified in 2010 and 15
temporary repairs were made. In 2017, it was noticed that 16
the leak had become significant and one more temporary 17
repair was made and annual inspections conducted. However, 18
the 2018 annual inspection discovered more leakage so the 19
replacement of the bushings and regasketing of the bushing 20
terminal plate was performed. 21
Q. Why do pulverizers require major rebuilds? 22
A. Pulverizers are utilized to grind coal to fine 23
dust before being transported to burner fronts. This 24
process wears out roll wheel assemblies, table grinding 25
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Idaho Power Company
segments, and the interior of pulverizer equipment. As a 1
result, the normal operating life cycle of a Unit 2
2pulverizer is roughly 18 to 24 months. 3
Q. How does the plant monitor the life cycle of a 4
pulverizer? 5
A. Routine inspections are performed at 3,000 6
hours and required maintenance is performed to ensure the 7
maximum life of the pulverizer rebuild. 8
Q. What did the major rebuild of the Unit 2 9
pulverizer entail? 10
A. Typically, major pulverizer overhauls, 11
required for continued reliable operation, include 12
replacements of roll wheels, air seals, coal shields, 13
bearings, wear resistant ceramic liners, classifier vanes, 14
coal feeder wear components, spring frame wear plate, and 15
the pyrites plow. A pulverizer overhaul was scheduled for 16
2019 but due to reduced run times for Unit 2, a full 17
overhaul was not yet needed. Instead, the project consisted 18
of purchasing three refurbished trunnion wheel assemblies 19
as capital spares. 20
Q. What is the benefit to purchasing capital 21
spares? 22
A. The capital spares will allow the capital 23
maintenance outages to be completed on an as needed basis, 24
as opposed to during the routine inspection, when the 25
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Idaho Power Company
pulverizers’ hours of operation and level of wear justifies 1
the overhauls. 2
Q. What was the next largest reliability-related 3
investment? 4
A. In 2019, the Unit 1D pulverizer roll wheel 5
assembly failed, resulting in two separate project 6
identifications, one associated with the repair and one 7
with the replacement, for investments totaling 8
approximately $159,000 and $47,000, respectively. 9
Q. What is the importance of the pulverizer roll 10
wheel assembly? 11
A. Black Butte coal requires all four pulverizers 12
to achieve full load of a unit. In September 2019, plant 13
personnel reported high amps on the Unit 1 pulverizer drive 14
motor. Unit 1 had been experiencing much higher-than-15
expected availability requirements; the 1D coal pulverizer 16
exceeded 20,000 hours of operation with significant wear 17
and parts deteriorated beyond the service life 18
expectations. Upon inspection, it was found that one of 19
the three wheel assemblies was cracked and not rotating 20
freely due to a bearing failure. 21
Q. If Valmy had been primarily operating only in 22
summer months, why was the replacement necessary in 2019? 23
A. The plant was coming up on its annual testing 24
and certification of the cold reheat safety valves, a 25
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Idaho Power Company
compliance requirement of the annual State of Nevada Boiler 1
Operating Permit, and needed to reach full load status, 2
requiring all four pulverizers. Due to the wear, there were 3
sizing differences of the three roll wheels’ diameters, 4
requiring the replacement of all three of the roll wheel 5
assemblies on the Unit 1D pulverizer. 6
Q. Please describe the next project associated 7
with investments required to maintain reliable operations 8
of Valmy. 9
A. Approximately $151,000 in investments were 10
made in the boiler equipment wash piping in 2021. A 11
section of the boiler equipment wash piping, which is used 12
to fill both circulating water systems prior to start-up, 13
failed. The underground piping was the original piping put 14
in during construction in 1979. Using alternative means to 15
fill the circulating water systems is very time consuming 16
and results in start-up delays, thus requiring the 17
replacement of the underground equipment wash piping. 18
Q. What was the next largest investment required 19
to maintain reliability at Valmy? 20
A. In 2019, the recoating of the condenser inlet 21
tube sheet was required contributing to approximately 22
$108,000 of the Valmy investments. The condenser inlet 23
tube sheet of a unit is exposed to erosion from particles 24
and turbulence in the circulating water. It is coated with 25
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Idaho Power Company
a wear resistant coating to protect the metal tube sheet 1
and condenser tube ends. The coating on Unit 2 had worn to 2
the point that significant portions of bare tube and tube 3
ends were exposed. 4
Q. What happens if it is left exposed? 5
A. When exposed, the tube ends will erode and can 6
result in tube failure and leakage of circulated water into 7
the steam side of the condenser, contaminating the boiler 8
water. Recoating of the tube sheet was required. However, 9
when the recoating began, the plant was able to repair some 10
of the existing waterbox coating resulting in project costs 11
lower than initially estimated. 12
Q. What additional investments were made solely 13
for reliability purposes? 14
A. The remaining 15 projects associated with 15
investments for reliable operations of Valmy made between 16
the January 1, 2019, through December 31, 2021, time period 17
were all under $100,000. They included (1) the replacement 18
of the coal handling conveyor following sustained run time 19
failure, (2) the purchase and installation of two redundant 20
1000 KVA transformers that power the coal handling system 21
following failure beyond economic repair, (3 and 4) two 22
projects associated with the motor of the Unit 1 23
circulating water pump that failed following a ground 24
fault, one investment associated with the replacement of 25
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Idaho Power Company
the motor and the second with the rewind of the failed 1
motor for use as a capital spare, (5) the refurbishment of 2
the failed Unit 2D pulverizer motor, (6) the installation 3
of a condensate pump rotating element to correct for low 4
condensate pressure, (7 and 8) two projects to ensure cyber 5
security compliance, the movement of individual servers to 6
a high availability server cluster capable of resisting 7
hardware failure and the replacement of several Human 8
Machine Interfaces and an Industrial Control System network 9
configuration change, (9) the installation of the spare 10
Unit 1A primary air fan motor due to damage, (10) the 11
replacement of two Electronic Deionization unit modules to 12
ensure very pure water for the boiler, (11) a new fly ash 13
blower to convey ash in order to prevent the baghouse 14
hoppers from overflowing due to internal wear and damage, 15
(12) new east to west first pass reverse osmosis membranes 16
as required every two years, (13) an upgrade of the revenue 17
meter required when Idaho Power exited participation in 18
operations of a Valmy unit, (14) refurbishment of the block 19
valve that supplies extraction steam to Unit 1 first point 20
feedwater heater, and (15) the Unit 1B pulverizer rebuild. 21
Exhibit No. 2 provides additional information for each 22
project including the total investment amount and a 23
detailed project description and justification. 24
Q. How have these 23 investments required for the 25
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Idaho Power Company
continued reliable operations of Valmy contributed to the 1
additions at the plant since January 1, 2019? 2
A. At $2.04 million, the investments for 3
reliability purposes are the largest expenditures made at 4
Valmy since 2018, making up 44 percent of the total 5
projects. 6
Q. You mentioned some of the investments over 7
$20,000 were made for a combination of either reliability, 8
environmental compliance, or safety purposes. Were there 9
any additional investments for which the purpose included a 10
reliability component? 11
A. Yes. There were eight projects for a 12
combination of reliability and safety purposes and three 13
for a combination of environmental and reliability 14
purposes. 15
Plant Reliability and Safety Investments 16
Q. Please describe those projects over $20,000 17
that have been identified as required for reliability and 18
safety purposes. 19
A. The largest investment made at Valmy during 20
the January 1, 2019, through December 31, 2021, time period 21
was for a combination of reliability and safety purposes. 22
In 2021, $1.24 million was spent to fix the Unit 2 turbine 23
high pressure/intermediate pressure (“HP/IP”) section shell 24
steam leaks. 25
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Idaho Power Company
Q. What caused the HP/IP section shell steam 1
leaks on the Unit 2 turbine? 2
A. Beginning in 2015, the Unit 2 steam turbine 3
HP/IP shell experienced five steam leaks from the mating 4
surfaces of the steam turbine HP/IP upper and lower shells. 5
Each steam leak damaged the two turbine shells by eroding 6
the mating surfaces material and providing further paths 7
for the superheated steam to escape from the turbine HP/IP 8
shells. At the time, previous repairs did not fix the 9
eroded mating surfaces or the compromised connection 10
hardware that compresses the two shell halves together to 11
form the mating surfaces seal. 12
Q. What happens when the mating surfaces and 13
connection hardware is not repaired? 14
A. Connecting hardware eventually wears out, only 15
enduring a limited number of tightening and loosening 16
cycles before the connecting hardware loses its strength 17
and the ability to provide the compressive forces necessary 18
to form the mating surfaces seal of the two shell halves. 19
This loss of connecting hardware strength is also 20
compounded by the high temperature during operations 21
causing the plastic deformation of the steel. This process 22
is known as creep. 23
Q. How did the creeping compound the issues with 24
the HP/IP shells? 25
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Idaho Power Company
A. The plastic deformation, in conjunction with 1
applied stresses, can also warp and distort both the 2
connecting hardware and the HP/IP shells themselves. A 3
‘tapped stud’ threads into the lower shell half and a large 4
nut is installed on the upper portion of the tapped stud 5
and tightened to apply the compressive force to the two 6
shell mating surfaces. 7
Q. Were the tapped studs of the HP/IP shells 8
affected? 9
A. Yes. A minimum of six tapped connecting studs 10
are known to have been compromised in some fashion, mostly 11
warpage. 12
Q. What was the extent of the investments 13
necessary to repair and prevent future HP/IP section shell 14
steam leaks? 15
A. This project replaced the connecting hardware, 16
which was no longer providing sufficient consistent 17
compressive force, with new hardware and refurbished the 18
mating surfaces of the two HP/IP shells. The two turbine 19
HP/IP turbine shells were separated, and the mating 20
surfaces were refurbished with a combination of welding and 21
machining. In addition, ten tapped connecting studs and 22
nuts on each side of the HP/IP turbine section in the areas 23
of the five steam leaks were replaced with new tapped 24
connecting studs and nuts. The tapped stud threads in the 25
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Idaho Power Company
lower half shell were also repaired as necessary. The 1
tapped studs replacement, lower half thread repairs and 2
HP/IP shell mating surfaces refurbishment were made after 3
the two HP/IP shells were separated. These repairs 4
corrected the known root causes and corrected for the 5
turbine HP/IP section shell steam leaks. 6
Q. What additional investments required for both 7
safety and reliability purposes were made? 8
A. In November 2017 an evaluation of the fire 9
protection systems was performed that determined the 10
refurbishment or replacement of the systems was required 11
due to degradation of the existing system, through a 12
combination of worn out and/or outdated components and 13
systems. As a result, the refurbishment of the Early 14
Warning Smoke Detection system was performed, the Unit 1 15
and Unit 2 stand-pipe booster pipes were replaced, the fire 16
alarm control panels and associated controls and alarms 17
were replaced, the deluge valves were replaced, and the 18
required flow testing of the electric fire pump and the 19
diesel fuel tank system was performed. The project 20
concluded in 2019 for total investments of approximately 21
$263,000. 22
Q. Please describe the additional investments 23
made between January 1, 2019, and December 31, 2021, 24
classified as required for reliability and safety purposes. 25
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Idaho Power Company
A. The next set of investments over $20,000 made 1
for reliable and safe operation of the plant were required 2
because of the age of the existing investment and the 3
associated wear and tear, including the replacement of the 4
Unit 2 stack elevator and transportation fleet at the 5
plant. The stack elevator was installed with Unit 2 in 6
1984 and replacement parts had become obsolete. On several 7
occasions the elevator stopped operating properly during 8
the installation of environmental compliance equipment and 9
prior to scheduled emission testing, causing delayed 10
installation timelines. A total of $107,341 was invested 11
to complete the elevator replacement including the car, 12
brake assembly, drive motor and gearbox, electrical system 13
replacement and call system replacement. 14
In 2020, approximately $88,000 was spent to replace 15
some of the van transportation fleet due to concern with 16
the safety and reliability. The Valmy fleet was aging and 17
reaching high mileage, traveling approximately 1,650 miles 18
for maintenance and 4,575 miles for operations/fuels per 19
month. The vans transport employees to and from the remote 20
plant site, 24 hours a day, seven days a week, which is a 21
standard in northern Nevada set by local mining companies. 22
Three of the existing nine vans were replaced as each van 23
was over ten years old with between 190,000 to 256,000 24
miles. 25
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Idaho Power Company
Q. What were the remaining four investments made 1
for reliability and safety purposes between January 1, 2
2019, and December 31, 2021? 3
A. The remaining investments identified as 4
necessary for reliable and safe operations of Valmy were 5
all under $100,000 and include (1) the refurbishment of the 6
trisector air heater expansion joint following damage from 7
thermal expansion, rust, acid condensation and erosion, (2) 8
the replacement of the Unit 2 desuperheater due to thermal 9
stress cracking and the potential for steam leaks, (3) a 10
software update to the system that monitors critical 11
rotating equipment at Valmy and the replacement of the 12
associated communication cards, and (4) the refurbishment 13
of the first point feedwater inlet valve on Unit 1. 14
Q. How have these projects, necessary for the 15
continued reliable and safe operations of Valmy, 16
contributed to the additions at the plant since January 1, 17
2019? 18
A. The investments made at Valmy for reliability 19
and safety purposes during the January 1, 2019, through 20
December 31, 2021, time period total $1.84 million, or 39 21
percent of the total projects. 22
Q. Were there any additional investments made at 23
Valmy between January 1, 2019, and December 31, 2021, that 24
included a purpose classification for continued reliable 25
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Idaho Power Company
operations of the plant? 1
A. Yes. There were three projects associated 2
with continued reliable operations of Valmy as well as 3
required for environmental compliance. 4
Plant Reliability and Environmental Compliance Investments 5
Q. What were the largest Valmy investments 6
required for with continued reliable operations and 7
environmental compliance purposes? 8
A. All three investments made at Valmy between 9
January 1, 2019, and December 31, 2021, and identified as 10
required for both continued reliable operations and 11
environmental compliance were associated with the scrubber 12
atomizer wheels on Unit 2. The dry scrubber on Unit 2 13
utilizes nine atomizing spray machines, three atomizers per 14
scrubber vessel, to atomize a lime/recycled fly ash mixed 15
slurry that reacts with the sulfur dioxide in the flue gas 16
to produce calcium sulfate. The solid calcium sulfate 17
particles are then collected along with fly ash in the 18
baghouse. 19
To accomplish this, the atomizer wheel rotates at 20
approximately 13,000 revolutions per minute and centrifugal 21
force shears the lime/recycled ash slurry into very small 22
droplets for intimate liquid/gas contact. The force of the 23
shearing slurry slowly erodes the atomizer wheels which 24
require routine replacement. An atomizer wheel can be 25
BARRETTO, DI 24
Idaho Power Company
expected to last for 10,000 to 12,000 hours in service. In 1
2019 the procurement of six new atomizer wheels was 2
required. Five of the atomizer wheels that were at the end 3
of their service life were replaced in 2020 and 2021, all 4
to ensure the reliable operations of Valmy during the 5
summer peak season. 6
Environmental Compliance Investments 7
Q. What investments were made at Valmy solely for 8
environmental compliance? 9
A. There were four investments made at Valmy 10
between January 1, 2019, and December 31, 2021, for which 11
the purpose was environmental compliance. The first, for 12
approximately $220,000, included the installation of nine 13
new ground water monitoring wells. 14
Q. Why were the new ground water monitoring wells 15
required? 16
A. Ground water elevation at Valmy had risen 17
noticeably over the last six to eight years, presumably due 18
to cessation of dewatering activities at the nearby Lone 19
Tree Mine. As a result, the screened interval intake of 20
several wells was nearly fully submerged. 21
Q. Are there guidelines in place for appropriate 22
groundwater levels? 23
A. Yes. According to Nevada Division of 24
Environmental Protection (“NDEP”) monitoring well 25
BARRETTO, DI 25
Idaho Power Company
guidelines, the groundwater level should be within the 1
screened interval level to obtain an accurate water level 2
reading. Any reported ground water levels above the top 3
screen level are considered invalid. At the time, of the 4
Valmy plant’s 14 ground water monitoring wells, five were 5
reading above the top screen level and four were close. 6
Q. What would happen if the groundwater levels 7
were not addressed? 8
A. If the wells were not redrilled, plugged, 9
abandoned or replaced, the existing wells may have become 10
non-compliant with the regulatory intent of monitoring the 11
potential impacts of operating the facilities’ landfill and 12
evaporation ponds. In addition, if not in compliance, the 13
NDEP can order similar action. As a result, the plant 14
installed nine new ground water monitoring wells. 15
Q. Please describe the remaining investments made 16
at Valmy for environmental compliance. 17
A. Approximately $21,000 was spent to replace the 18
Unit 2B scrubber lime transfer blower which overheated and 19
failed, another $13,000 for the replacement of the low 20
nitrogen-oxide burner nozzles of Unit 1 to remain compliant 21
with the Mercury and Air Toxics Standards, and finally 22
$1,000 of costs associated with the replacement of the 23
existing sorbent trap mercury monitoring equipment closed 24
in 2019. 25
BARRETTO, DI 26
Idaho Power Company
Q. Were there any additional investments made at 1
Valmy between January 1, 2019, and December 31, 2021, that 2
included a purpose classification for environmental 3
compliance? 4
A. Yes. There was one project associated with 5
environmental compliance and the continued safe operations 6
of Valmy. 7
Environmental Compliance and Safety Investments 8
Q. Please describe the required investment for 9
environmental compliance and safety. 10
A. The three dry scrubber vessels on Unit 2 often 11
suffer severe scaling and/or debris material buildup as 12
scale is dislodged from the scrubber vessel walls. The 13
scale and buildup can be severe enough that several times 14
per year the unit is curtailed by 70 MWs while the scale 15
and buildup are removed from the vessel walls and the 16
outlet duct via the existing debris chute and from the 17
outlet duct door. The debris material is then collected and 18
transported to the ash landfill. The removal of the debris 19
is required under the Mercury and Air Toxic Standards 20
regulations. 21
In 2020, approximately $127,000 in project costs 22
were incurred to enlarge the existing Unit 2 scrubber 23
vessel debris chute and install three 24-inch diameter 24
hydraulically actuated knife gate valves. The purpose was 25
BARRETTO, DI 27
Idaho Power Company
to allow for the faster and safer removal and collection of 1
the scale, sludge and debris for disposal in the ash 2
landfill. The investment reduced the duration of forced 3
outage by 50 percent. In addition, automation of the 4
valves to open the scrubber vessel, which previously 5
required personnel to perform via a ladder, rectified a 6
safety concern. 7
Safety Investments 8
Q. Were there any investments made at Valmy since 9
2018 that were solely for the safety of plant personnel? 10
A. Yes. The final investment made at Valmy 11
between the January 1, 2019, through December 31, 2021, 12
time period that I did not previously discuss was made as a 13
result of a safety concern at the plant. In the design of 14
the Unit 2 boiler, no provisions were made to provide 15
attachment points for cables supporting the furnace sky 16
climber during outages. 17
Q. What is the furnace sky climber used for? 18
A. These platform type sky climbers are used by 19
maintenance and engineering to provide a moveable aerial 20
platform in the furnace for inspections and repairs. 21
Attachments for the two cables supporting each sky climber 22
consisted of wire slings placed around structural steel or 23
pipes above the penthouse. Placement of these slings, each 24
year prior to outage work, was a significant fall hazard to 25
BARRETTO, DI 28
Idaho Power Company
maintenance personnel, even with appropriate fall 1
protection equipment. To mitigate the fall hazard and 2
provide more substantial, reliable, and safer attachment 3
points for the sky climber support cables, a permanent, 4
engineered attachment structure was installed, consisting 5
of welded attachments to structural steel with steel ropes 6
and spreader beams to position reachable attachment points 7
directly above the sky climber cable furnace penetration 8
points. Total projects costs for this necessary safety 9
improvement were $33,051. 10
Q. Please summarize the investments that were 11
made at Valmy over $20,000 or were specific to Unit 1 that 12
make up the $4.66 million for which Idaho Power is 13
requesting a prudence determination. 14
A. Of the 40 projects for which a detailed 15
project description and investment purpose classification 16
was provided, 23 were for the continued reliable plant 17
operations totaling $2.04 million, another $255,000 was 18
associated with the four projects required for 19
environmental compliance, one project at $33,000 was for 20
the safe operations of the plant, and the remaining 12, 21
which were for the combination of either reliability, 22
environmental compliance, or safety, contributed to $2.30 23
million of the total investments made at Valmy between 24
January 1, 2019, through December 31, 2021. 25
BARRETTO, DI 29
Idaho Power Company
III. FORECASTED VALMY INVESTMENTS 1
Q. Company witness Courtney Waites indicated the 2
Valmy balancing account true-up included an update to the 3
forecasted investment component of the levelized revenue 4
requirement. Please explain the investments expected to be 5
made over the remaining life of the plant. 6
A. While the Parties are cognizant of the 7
approaching end-of-life of Valmy, there are investments 8
necessary to ensure the plant remains operational in a 9
safe, efficient, and reliable matter. Under the Framework 10
Agreement, because Idaho Power has exited participation in 11
Unit 1 operations, the Company is no longer responsible for 12
capital costs associated with that unit, so the forecast 13
does not include investments expected in Unit 1. 14
However, Idaho Power is still responsible for common 15
facility investments and Unit 2 investments until the last 16
unit is exited. The latest forecast, presented in 17
Confidential Exhibit No. 3, includes a project spend during 18
the 2022 through 2025 time period approximately $7.57 19
million higher than previously anticipated. The largest 20
expenditures are associated with an additional Human 21
Machine Interface and server update, the replacement of 22
Unit 2 components and pulverizer roll wheels due to normal 23
wear and tear, and another production well replacement. 24
Q. What additional investments does the Company 25
BARRETTO, DI 30
Idaho Power Company
anticipate will be required prior to Idaho Power’s exit 1
from operations at Valmy? 2
A. The remaining investments anticipated between 3
2022 and 2025 are all associated with the annual blanket 4
projects for pumps, valves and motors, and routine 5
infrastructure to maintain the reliable safe operations of 6
the plant. 7
Q. What are blanket projects? 8
A. Blanket projects are intended to capture 9
capital issues that arise, typically equipment failures 10
that were unplanned and therefore not individually 11
identified and budgeted. 12
VI. CONCLUSION 13
Q. Please summarize your testimony. 14
A. The Preferred Portfolio identified in the 2021 15
IRP continues to reflect an exit from Valmy Unit 2 in 2025 16
as a more favorable economic outcome when compared to an 17
earlier exit. Idaho Power has been required to make 18
investments at Valmy since 2018 and has been actively 19
involved in the capital spend decision making process at 20
the plant. Of the 40 projects identified in which Idaho 21
Power’s share of the investments was more than $20,000 or 22
the investment was made in Unit 1, 23 were for the 23
continued reliable plant operations totaling $2.04 million, 24
another $255,000 was associated with the four projects 25
BARRETTO, DI 31
Idaho Power Company
required for environmental compliance, one project at 1
$33,000 was for the safe operations of the plant, and the 2
remaining 12, which were for the combination of either 3
reliability, environmental compliance, or safety, 4
contributed to $2.30 million of the total investments made 5
at Valmy. While the Parties have been cognizant of the 6
approaching end-of-life of Valmy, the investments made were 7
prudent and required to ensure the plant remains 8
operational in a safe, efficient, and reliable matter. 9
Q. Does this conclude your testimony? 10
A. Yes. 11
12
13
14
BARRETTO, DI 32
Idaho Power Company
DECLARATION OF LINDSAY BARRETTO 1
I, Lindsay Barretto, declare under penalty of 2
perjury under the laws of the state of Idaho: 3
1. My name is Lindsay Barretto. I am employed 4
by Idaho Power Company as the 500kV and Joint Projects 5
Senior Manager. 6
2. On behalf of Idaho Power, I present this 7
pre-filed direct testimony and Exhibit Nos. 2 and 3 in this 8
matter. 9
3. To the best of my knowledge, my pre-filed 10
direct testimony and exhibits are true and accurate. 11
I hereby declare that the above statement is true to 12
the best of my knowledge and belief, and that I understand 13
it is made for use as evidence before the Idaho Public 14
Utilities Commission and is subject to penalty for perjury. 15
SIGNED this 28th day of February 2022, at Boise, 16
Idaho. 17
18
Signed: 19
20
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-22-05
IDAHO POWER COMPANY
BARRETTO
TESTIMONY
EXHIBIT NO. 2
Project Descr V1 V2 VC Total Purpose Project Description/Justificatio
27574743 VALMY 98482392 V2 REPLACE TURBINE HP/IP SECTION 1,240,96 1,240,96 Reliability/Safet
The Unit 2 steam turbine high pressure/intermediate pressure (HP/IP) shell experienced five steam leaks from the mating surfaces of the steam turbine HP/IP
upper and lower shells, beginning in 2015. Each steam leak damaged the two turbine shells by eroding the mating surfaces material and providing further
paths for the superheated steam to escape from the turbine HP/IP shells. At the time, previous repairs did not fix the eroded mating surfaces or the
compromised connection hardware that compresses the two shell halves together to form the mating surfaces seal. Connecting hardware wears it out, only
enduring a limited number of tightening and loosening cycles before the connecting hardware loses its strength and the ability to provide the compressive
forces necessary to form the mating surfaces seal of the two shell halves. This loss of connecting hardware strength is also compounded by the high
temperature during operations causing the plastic deformation of the steel in a process known as creep. This plastic deformation in conjunction with applied
stresses can also warp and distort both the connecting hardware and the HP/IP shells themselves. A ‘tapped stud’ threads into the lower shell half and a large
nut is installed on the upper portion of the tapped stud and tightened to apply the compressive force to the two shell mating surfaces. A minimum of six
tapped connecting studs are known to have been compromised in some fashion, mostly warpage. This project replaced the connecting hardware, which was
no longer providing sufficient consistent compressive force, with new hardware and refurbished the mating surfaces of the two HP/IP shell mating surfaces.
The two turbine HP/IP turbine shells were separated and the mating surfaces were refurbished with a combination of welding and machining. In addition,
ten tapped connecting studs and nuts on each side of the HP/IP turbine section in the areas of the five steam leaks were replaced with new tapped
connecting studs and nuts. The tapped stud threads in the lower half shell were also repaired as necessary. The tapped studs replacement, lower half thread
repairs and HP/IP shell refurbishment were made after the two HP/IP shells were separated. These repairs corrected the known root causes, compromised
mating surfaces and compromised connecting hardware, that were causing the turbine HP/IP section shell steam leaks.
27514784 VALMY 98438396 VC FREEZE PROTECTION HEATERS,541,325 541,325 Reliability
When the Valmy operating schedule shifted to running the units in only the summer months, and to be in long‐term layup during the remaining months of
the year, it was determined that with both units offline there was no auxiliary steam to provide heat to the turbines, boilers and buildings to keep them dry
and above the dew point, per the long‐term layup plan. The plant was renting portable electric space heaters to sufficiently heat the plant buildings and
equipment during the layup period. It was determined that the purchase of the heaters was more cost effective than renting. In addition, the purchase and
installation included four water‐to‐air dry finned coolers which cool the component cooling system on each unit and exhaust warm dry air into the lower
level of the turbine building, reducing the number of electric heaters required to be purchased.
27517151 VALMY 98438233 VC FIRE PROTECTION SYSTEM, REF 262,492 262,492 Reliability/Safet
In November 2017, an evaluation of the fire protection systems was performed that determined the refurbishment or replacement of the systems was
required due to degradation of the existing system, through a combination of worn out and/or outdated components and systems. This project included the
refurbishment of the Early Warning Smoke Detection system, the replacement of the Unit 1 and Unit 2 stand‐pipe booster pipes, the replacement of the fire
alarm control panels and associated controls and alarms, replacement of deluge valves, the electric fire pump and the required flow testing on the diesel fuel
tank s stem.
27528897 VALMY 98455128 V2 PIN MIXER/UNLOADER, REBUILD 224,78 224,78 Reliability
The existing original Unit 2 pin mixer (wet fly ash unloader) required replacement due to normal wear and tear. In addition, in 2018 an ash hauling dump
truck damaged the Unit 2 wet fly ash unloader, further impacting the reliability of the pin mixer. The pin mixer/unloader was rebuilt prior to the summer run
to avoid the potential of serious failure of the non‐redundant equipment.
27555279 VALMY 98455852 VC GROUND WATER MONITORING WEL 219,799 219,79 Environmental
Ground water elevation at Valmy had risen noticeably over the last 6‐8 years, presumably due to cessation of dewatering activities at the nearby Lone Tree
Mine, resulting in the screened interval intake of several wells becoming fully submerged. According to Nevada Division of Environmental Protection (NDEP)
monitoring well guidelines, the groundwater level should be within the screened interval level to obtain an accurate water level reading. Any reported
ground water levels above the top screen level are considered invalid. Valmy has 14 total ground water monitoring wells, of which five were reading above
the top screen level and four were close. If the wells were not redrilled, plugged, abandoned or replaced, the existing wells may have become non‐
compliant with the regulatory intent of monitoring the potential impacts of operating the facilities landfill and evaporation ponds. In addition, if not in
compliance, the NDEP can order similar action. These costs are associated with the installation of nine new ground water monitoring wells.
27527353 VALMY 98438400 V2 GENERATOR BUSHINGS, REPLACE 106,64 106,64 Reliability
The terminal plate gaskets for the high voltage bushings of the generator were worn out and there was indication of bushing gaskets leaking as the viscasil
was seeping through the bushing gaskets. Bushing gasket leakage could lead to catastrophic failure of the generator. The issue was first identified in 2010
and temporary repairs were made. In 2017, it was noticed that the leak had become significant and one more temporary repair was made and annual
inspections conducted. The 2018 annual inspection discovered more leakage so the replacement of the bushings and regasketing of the bushing terminal
plate was performed.
27547460 VALMY 98377358 V2 PULVERIZER "A" MAJOR REBUILD‐2016 165,54 165,54 Reliability
Pulverizers are utilized to grind coal to fine dust before being transported to burner fronts. This process wears out roll wheel assemblies, table grinding
segments, and the interior of pulverizer equipment. The normal operating life cycle of a Unit 2 pulverizer is roughly 18 to 24 months. Routine inspections are
performed at 3,000 hours and required maintenance is performed to ensure the maximum life of the pulverizer rebuild. Typically, major pulverizer overhauls
for continued reliable operation of Unit 2 and include replacements of roll wheels, air seals, coal shields, bearings, wear resistant ceramic liners, classifier
vanes, coal feeder wear components, spring frame wear plate, and the pyrites plow. A pulverizer overhaul was scheduled for 2019 but due to reduced run
times for Unit 2, a full overhaul was not yet needed. Instead, the project consisted of purchasing three refurbished trunnion wheel assemblies as capital
spares. The capital spares will allow the capital maintenance outages to be completed on an as needed basis, as opposed to during the routine inspection,
when the pulverizers’ hours of operation and level of wear justifies the overhauls.
27545751 VALMY 98466935 V1 PULVERIZER D ROLL WHEEL ASS 159,45 159,45 Reliability
In April 2019, the Unit 1D pulverizer roll wheel assembly failed. Black Butte coal requires all four pulverizers to achieve full load. The roll wheel assembly
was replaced. In addition, in September 2019, plant personnel reported high amps on the Unit 1 pulverizer drive motor. Unit 1 had been experiencing much
higher than expected availability requirements; the 1D coal pulverizer exceeded 20,000 hours of operation with significant wear and parts deteriorated
beyond the service life expectations. Upon inspection, it was found that one of the three wheel assemblies was cracked and not rotating freely due to a
bearing failure. The plant was coming up on its annual testing and certification of the cold reheat safety valves, a compliance requirement of the annual State
of Nevada Boiler Operating Permit, and needed to reach full load status, requiring all four pulverizers. Due to the wear, there were sizing differences of the
three roll wheels’ diameters, requiring the replacement of all three of the roll wheel assemblies.
27591516 VALMY 98494358 VC EQUIPMENT WASH PIPING REPLACEMENT 150,96 150,96 Reliability
A section of boiler equipment wash piping that is used to fill both circulating water systems prior to start up failed. This was the original underground piping
from construction in 1979. Using alternative means to fill the circulating water systems is very time consuming and results in start up delays. These costs
included the replacement of the underground equipment wash piping.
27549554 VALMY 98467485 V2 SCRUBBER OUTLET DUCT PLUGGA 126,75 126,75 Safety / Environmental
The three dry scrubber vessels on Unit 2 often suffer severe scaling and/or debris material buildup as scale is dislodged from the scrubber vessel walls. The
scale and buildup can be severe enough that several times per year the unit is curtailed by 70 MW’s while the scale and buildup are removed from the vessel
walls and the outlet duct via the existing debris chute and from the outlet duct door. The debris material is then collected and transported to the ash landfill.
The removal is also required under the Mercury and Air Toxic Standards regulations. This project enlarged the existing Unit 2 scrubber vessel debris chute
and installed three 24‐inch diameter hydraulically actuated knife gate valves to allow for the faster and safer removal and collection of the scale, sludge and
debris for disposal in the ash landfill. The duration of forced outage was decreased by half and automated the valves to open the scrubber vessel, which
previously required personnel to perform via a ladder, improving safety.
27533137 VALMY 98455854 V2 ATOMIZER WHEELS, REPL 115,962 115,962 Environmental/Reliability
A dry scrubber utilizes nine atomizing spray machines to atomize a lime/recycled fly ash mixed slurry that reacts with the sulfur dioxide in the flue gas to
produce calcium sulfate. In 2018, Valmy was expected to be used as a seasonal facility and to only run during the summer peak months. The plant was
utilized more than anticipated and stayed on through the winter of 2018 and into the spring of 2019, primarily due to the impacts of the Enbridge pipeline
explosion that occurred in October 2018. The extended run time amounted to many more hours on the wheels than originally anticipated requiring the
procurement of six new atomizer wheels. The re lacement of the wheels ensured the plant’s reliabilit for the 2019 summer peak season.
27579441 VALMY 98485333 V2 SCRUBBER ATOMIZER WHEELS, R 109,72 109,72 Environmental/Reliability
The dry scrubber on Unit 2 utilizes nine atomizing spray machines (three atomizers per scrubber vessel) to atomize a lime/recycled fly ash mixed slurry that
reacts with the sulfur dioxide in the flue gas to produce calcium sulfate. The solid calcium sulfate particles are then collected along with fly ash in the
baghouse. To accomplish this the atomizer wheel rotates at approximately 13,000 revolutions per minute and centrifugal force shears the lime/recycled ash
slurry into very small droplets for intimate liquid/gas contact. The force of the shearing slurry slowly erodes the atomizer wheels which require routine
replacement. An atomizer wheel can be expected to last for 10,000 – 12,000 hours in service. This project replaced five of the atomizer wheels that were at
the end of their service life and was necessar to ensure the plant’s reliabilit for the 2021 summer peak season.
27557530 VALMY 98473784 V2 SCRUBBER ATOMIZER WHEELS, R 108,81 108,81 Environmental/Reliability
The dry scrubber on Unit 2 utilizes nine atomizing spray machines (three atomizers per scrubber vessel) to atomize a lime/recycled fly ash mixed slurry that
reacts with the sulfur dioxide in the flue gas to produce calcium sulfate. The solid calcium sulfate particles are then collected along with fly ash in the
baghouse. To accomplish this the atomizer wheel rotates at approximately 13,000 revolutions per minute and centrifugal force shears the lime/recycled ash
slurry into very small droplets for intimate liquid/gas contact. The force of the shearing slurry slowly erodes the atomizer wheels which require routine
replacement. An atomizer wheel can be expected to last for 10,000 – 12,000 hours in service. This project replaced five of the atomizer wheels that were at
the end of their service life and was necessary to ensure the plant’s reliability for the 2020 summer peak season.
VALMY PLANT ADDITIONS: Jan 1, 2019 - Dec 31, 2021
Exhibit No. 2 Case No. IPC-E-22-05 L. Barretto, IPC
Page 1 of 3
Project Descr V1 V2 VC Total Purpose Project Description/Justificatio
VALMY PLANT ADDITIONS: Jan 1, 2019 - Dec 31, 2021
27528895 VALMY 98455127 V2 CONDENSER INLET WATERBOX, R 108,02 108,02 Reliability
The condenser inlet tube sheet of a unit is exposed to erosion from particles and turbulence in the circulating water so it is coated with a wear resistant
coating to protect the metal tube sheet and condenser tube ends. The coating on Unit 2 had worn to the point that significant portions of bare tube and tube
ends were exposed. When exposed, the tube ends will erode and can result in tube failure and leakage of circulated water into the steam side of the
condenser, contaminating the boiler water. The scope of the project included the recoating of the tube sheet. When the recoating began, the plant was able
to repair some of the waterbox coating resulting in project costs lower than initially estimated.
27539687 VALMY 98462057 V2 STACK ELEVATOR, REPLACE 107,34 107,34 Reliability/Safet
The Unit 2 stack elevator reliability and safety was compromised due to the age of the elevator and replacement parts had become obsolete. The elevator
installed with Unit 2 was constructed in 1984. On several occasions the elevator stopped operating properly during the installation of environmental
compliance equipment and prior to scheduled emission testing, causing delayed installation timelines. The project included a complete elevator replacement
including the car, brake assembly, drive motor and gearbox, electrical system replacement and call system replacement.
27570622 VALMY 98481652 VC 5B COAL UNLOAD CONVEYER BELT, REPLACE VA 88,583 88,583 Reliability
Coal handling conveyor 5B sustained a run time failure resulting in severe damage to the conveyor belting, bend pulleys and to the bend pulley support
framing. Permanent repairs were made to the bend pulleys and bend pulley support framing. Temporary repairs were made to the damaged 5B building in
order to make the 5B belt train available for emergency use only if needed. Because Valmy was relying on only conveyors 5A and 6A for full delivery of coal
(two conveyors used in tandem are required), conveyor 5B was replaced in the event 5A or 6A became damaged or inoperable. Upon inspection of the drive
gearbox, it was determined a replacement was necessary. Quotes were received for a rebuild of the gearbox but it was determined a replacement was more
cost‐effective.
27555276 VALMY 98466597 VC VANS, REPLACE (3) VA 87,965 87,965 Reliability/Safet
The plant was concerned with the safety and reliability of the van transportation fleet. The Valmy fleet was aging and reaching high mileage, traveling
approximately 1,650 miles for maintenance and 4,575 miles for operations/fuels per month. The vans transport employees to and from the remote plant
site, 24 hours a day, seven days a week, which is a standard in northern Nevada set by local mining companies. The cost of the vans is partially offset by a
payroll deduction from each employee riding in the van. This project replaced three of the existing nine vans, each van is over ten years old with between
190,000 to 256,000 miles
27506993 VALMY 98437320 VC UNIT SUB 5A 5B 1000 KVA DRY TRANSORMER RPL 64,961 64,961 Reliability
The coal handling system is powered by two redundant 1000 KVA transformers. Both of the transformers have failed and were beyond economic repair so
the system was being run on a temporary transformer that is close enough in design to be used for temporary purposes only. Two redundant transformers
are necessary for reliable operation. If not remedied and the temporary transformer were to fail, the coal handling system would go down until a new or
rewound transformer is installed. The lead time for a new transformer is 8 to 10 weeks. This would result in a 100 percent derate on the units because there
would be no coal deliver to the plant. These costs were associated with the purchase and install of two new transformers.
27568576 VALMY 98478100 V2 TRISECTOR AIR HEATER EXPANSION JOINT REFUR 61,203 61,203 Reliability/Safet
The trisector air heater expansion joint suffered damage from thermal expansion, rust, acid condensation and erosion and failure was imminent. The
expansion joint was torn and leaking on the outlet side of the trisector air heater. Valmy's cycling operation compounds the fatigue and wear exposure from
thermal stress from cooling to ambient conditions when the unit is in reserve shutdown followed by heating back to operating temperatures in excess of 700
degrees Fahrenheit. Continued operation would likely cause deterioration, which would have resulted in an outage or derate, as well as a potential safety
concern and heat rate impact due to the hot air leakage. This repair was critical for reliability and safety.
27533144 VALMY 98459394 V1 CIRCULATION WATER PUMP 1A MOTOR, REPL 58,57 58,57 Reliability
In April 2019, the Unit 1 circulating water pump failed due to a motor ground fault. Absent a circulating water pump in service, Unit 1 would be de‐rated to
approximately 125 net MW output, or half its normal load. The motor was sent to a contract repair shop for evaluation where it was determined that a
complete motor rewind was required. At the request of the Western Electricity Coordinating Council, and because of the four to six‐week lead time
associated with the repairs, a new replacement motor was purchased so that the plant could meet reliability and availability needs. The rewind was
performed and used as a capital spare and a replacement motor was procured.
27533145 VALMY 98459395 V1 D1 PULVERIZER ROLL WHEEL ASSEMBLY, REPL 46,984 46,984 Reliability
In April 2019, the Unit 1D pulverizer roll wheel assembly failed. Black Butte coal requires all four pulverizers to achieve full load. The roll wheel assembly
was replaced. In addition, in September 2019, plant personnel reported over amping of the Unit 1 pulverizer drive motor. Unit 1 had been experiencing
much higher than expected availability requirements; the 1D coal pulverizer exceeded 20,000 hours of operation with significant wear and parts deteriorated
beyond the service life expectations. Upon inspection, it was found that one of the three wheel assemblies was cracked and not rotating freely due to a
bearing failure. The plant was coming up on its annual testing and certification of the cold reheat safety valves, a compliance requirement of the annual State
of Nevada Boiler Operating Permit, and needed to reach full load status, requiring all four pulverizers. Due to the wear, there were sizing differences of the
three roll wheels’ diameters, requiring the replacement of all three of the roll wheel assemblies.
27534969 VALMY 98455853 V2 PULVERIZER MOTOR 2D, REBUILD 44,28 44,28 Reliability
Unit 2 pulverizers have old and obsolete 600 HP electric motors. Due to the frequency of failures of the old motors, a spare motor is needed in order to
avoid long unit derates and costly expedited motor repair services. In October 2018, the new spare motor for the Unit 2 pulverizers was used to replace a
failed motor on 2D pulverizer, leaving no spare pulverizer motor for Unit 2. This project refurbished the failed 2D pulverizer motor for use as a spare for all
Unit 2 pulverizers.
27587933 VALMY 98492604 V2 CONDENSATE PUMP CAPITAL SPARE INSTALLATION 40,991 40,991 Reliability
Unit 2 was not able to achieve full load due to low condensate pressure. An engineering review showed deterioration of the pump performance. The pump
was last replaced in August 2012 due to failure of the rotating element. The deterioration was contributing to the unit's inability to achieve full load.
Installation of the capital spare condensate pump rotating element was performed to eliminate the issue.
27556791 VALMLY 98473462 VAL DMZ SERVER CLUSTER VA 37,130 37,130 Reliability
The configurations in the Valmy De‐Militarized Zone (“DMZ”) included five individual servers for each functional and protective service. One of the servers
had reached the end of its life because it was running on an outdated operating system that was no longer supported by Microsoft. As a result, the cyber
security patching was no longer available for that server. This project moved the many individual servers in the Valmy DMZ to a high availability server
cluster capable of resisting hardware failure and facilitating cyber security compliance.
27539686 VALMY 98459449 V1 1A CIRCULATING WATER PUMP M 35,96 35,96 Reliability
In April 2019, the Unit 1 circulating water pump failed due to a motor ground fault. Absent a circulating water pump in service, Unit 1 would be de‐rated to
approximately 125 net MW output, or half its normal load. The motor was sent to a contract repair shop for evaluation where it was determined that a
complete motor rewind was required. At the request of the Western Electricity Coordinating Council, and because of the four to six‐week lead time
associated with the repairs, a new replacement motor was purchased so that the plant could meet reliability and availability needs. The rewind was
performed and used as a capital spare and a replacement motor was procured.
27534970 VALMY 98458824 V2 AUXILIARY STEAM DESUPERHEAT 34,947 34,947 Reliability/Safet
Auxiliary steam for Unit 2 is supplied through a control station fed by either main steam or extraction steam. The supplied steam passes through a control
station and is reduced to auxiliary steam pressure at an elevated temperature. The steam then passes through the auxiliary steam desuperheater which is
cooled to an appropriate temperature by the introduction of high pressure feedwater being sprayed into the path of the steam while passing through. This
spraying action results in thermal stress cracking to the body of the desuperheater. The cracks in the desuperheater body will leak steam which becomes a
hazard to employees in the area. Without an operable desuperheater downstream carbon steel piping temperature limits would be exceeded as per ASME
B31.1 Power Piping Code which could damage or destroy the piping. Unit reliability and personnel safety are jeopardized without an operable auxiliary steam
desuperheater or Unit 1 being in operation to supply Unit 2 with auxiliary steam. Because a replacement has a 26 week lead time, a new one was ordered
and installed to replace the desuperheater and prevent failures.
27547697 VALMY 98468760 V1 PRIMARY AIR FAN A MOTOR, RE 33,88 33,88 Reliability
On October 31, 2019, the Unit 1 A Primary Air Fan motor inboard bearing overheated and failed while in service. The motor inboard bearing alarm sounded
and upon inspection of the motor, plant personnel discovered a large amount of smoke coming from the motor inboard bearing housing. The motor was
shut down and replaced with the existing spare motor. The damaged motor was refurbished to become a spare Primary Air Fan motor. Unit 1 Primary Air
Fans are used to convey fluidized coal from the pulverizers to the boiler burner through attached coal conduit piping. Without both Primary Air Fans, Unit 1
could not reach stable operation and would have been curtailed until late December 2019 while the damaged motor was repaired. While the costs appear as
2020 plant additions, the work was performed on Unit 1 in 2019 but final costs did not close to the project until early 2020.
Exhibit No. 2 Case No. IPC-E-22-05 L. Barretto, IPC
Page 2 of 3
Project Descr V1 V2 VC Total Purpose Project Description/Justificatio
VALMY PLANT ADDITIONS: Jan 1, 2019 - Dec 31, 2021
27551304 VALMY 98453212 V2 SKY CLIMBER ATTACHMENT PLATFORM, INSTALL 33,051 33,051 Safet
In the design of the Unit 2 boiler, no provisions were made to provide attachment points for cables supporting the furnace sky climber during outages. These
platform type sky climbers are used by maintenance and engineering to provide a moveable aerial platform in the furnace for inspections and repairs.
Attachments for the two cables supporting each sky climber consisted of wire slings placed around structural steel or pipes above the penthouse. Placement
of these slings, each year prior to outage work, was a significant fall hazard to maintenance personnel, even with appropriate fall protection equipment. To
mitigate the fall hazard and provide more substantial, safer and reliable attachment points for the sky climber support cables, a permanent, engineered
attachment structure was installed, consisting of welded attachments to structural steel with steel ropes and spreader beams to position reachable
attachment points directly above the sky climber cable furnace penetration points.
27531065 VALMY 98454279 VALMY TECHNOLOGY SECURITY UPDA 30,781 30,781 Reliability
A review of the cyber security profile revealed a vulnerability in several components through their obsolete and no longer securable operating systems and
software. The devices, which included laptops used to maintain the Industrial Control System (ICS) environment and several Human Machine Interfaces
(HMI) in the ICS network, must be replaced with HMIs that are able to be secured to the current standards. To do so, the software needed to be updated to
run the new hardware. In addition, one of the HMI's that was being replaced was not able to communicate as required for asset management and
monitoring. This project replaced several HMIs, made an ICS network configuration change, and updated software used in two ICS systems.
27577136 VALMY 98485331 VC EDI MODULES, REPLACE 2 28,976 28,976 Reliability
e servce life o the Elecronc Deonza on (EDI) un s use to ma e very pure wa er for the boer ma eup is 3‐4 years, base on sm ary insa e un s in
Northern Nevada. Longer periods of down time from seasonal operation require proper layup to prevent shortening of the service life. EDI life is monitored
by the varying voltage required to maintain the current to the electodes at 8.5 to 9.5 amps. When modules are clean, only 120‐130V is required. Fouled
modules require 400‐450V. Valmy's modules were running 150‐250V and it was anticipated that replacement of the modules would be required on one EDI
train in 2021 and the other EDI train in 2023. These two modules were installed in 2017. The project replaced two EDI modules.
27579435 VALMY 98486141 VC SYSTEM1 UPDATE 27,421 27,421 Reliability/Safet
This specific software is used to monitor the vibration and process data for the critical rotating equipment at Valmy, such as the pumps, generators, and
turbines. It is used to quickly and accurately diagnose equipment problems before failure, improving the plant's ability to plan for outages and maintain the
equipment. The version of the software installed throughout the generation fleet was reaching the end of its life and was no longer going to be supported by
the vendor. Absent vendor support, patches would not be available or bug fixes provided to keep the system up to date. To remain cyber secure, the
software would be required to be patched continually. This project upgraded the software to the latest version and replaced the required communication
cards that are compatible with the upgraded system.
27543734 VALMY 98464825 V1 FLY ASH BLOWER 1B, REPLACE 25,802 25,802 Reliability
A fly ash blower is needed to convey ash in order to keep the baghouse hoppers from overflowing which would lead to an eventual unit shutdown.
Inspection of the fly ash blower 1B after it began making unusual noises determined that the blower was not reliable for dependable service and failure was
imminent due to internal wear and damage. Plant reliability is increased as replacing the 1B fly ash blower ensures that there is a redundant blower to
convey ash and fluidize when needed to do so.
27539690 VALMY 98463011 V2 LIME TRANSFER BLOWER 2B, RE 20,983 20,983 Environmental
T e Unt 2 scru er ut zes a lime trans er ppng system to convey lime from one o two externay locate lime storage s os to t e scru er unt w ere t e
lime is used in process to remove sulfur dioxide limits for boiler flue gas as mandated by the NDEP. The lime transfer system was originally designed with
two redundant transfer blowers, one blower serving as the in‐service blower and the other serving as a backup or standby blower in the event of a failure.
With regard to the original design, having only 1 operable transfer blower is a risk to environmental compliance and could lead to reliability concerns or
reduced or no Unit 2 generation. Lime must be conveyed into the scrubber in order for sulfur dioxide emissions reduction to take place. The Unit 2 scrubber
lime transfer blower 2B overheated and failed, leaving the scrubber with only one operable blower to transfer lime. This project replaced the 2B lime
transfer blower, restoring system redundancy to its original design, preventing any potential environmental or reliability concerns.
27566786 VALMY 98475628 VC RO MEMBRANES, REPLACE 68/32 20,635 20,635 Reliability
First pass reverse osmosis membranes foul and plug over time. New membranes are required approximately every two years to maintain ultra‐pure
condensate for boiler makeup. This project replaced the east and west first pass reverse osmosis membranes which were last replaced in 2018.
27533141 VALMY 98459392 V2 1ST POINT HEATER DRAIN VALVE, REPL 18,07 18,07
27566788 VALMY 98478101 VC DIGITAL ALIGNMENT TOOL 16,892 16,892
27539683 VALMY 98455129 VC DATA LOGGERS, REPLACE 14,96 14,96
27533139 VALMY 98457380 VA HMI REPLACEMENT 14,622 14,622
27533143 VALMY 98459393 V1 1ST POINT FEEDWATER INLET VALVE, REFUR 14,56 14,56 Reliability/Safet
In August 2018 a steam leak to atmosphere from the pressure seal surface of the valve on Unit 1 was discovered. Disassembly and refurbishment was the
only way repairs could be made to the valve to avoid the burn hazard of leaking steam to plant personnel and ensure continued reliability of the unit’s
operation.
27537126 VALMY 98459140 V2 REVENUE METER, UPGRADE 14,443 14,443
27502697 VALMY 98434354 V1 LOW NOX BURNER NOZZLES, REP 13,14 13,14 Environmental
Mercury and Air Toxics Standards ("MATS") Rule 40 CFR 63.10021 require a burner and combustion control inspection, and combustion tuning every thirty‐
six months. During the inspection, completed in December 2017, significant degradations were noted on 22 thermocouples, 15 coal burner assemblies, and
refractory around all burners. This scope of work was identified as required to be completed to meet regulations and allow continued boiler operation.
27557532 VALMY 98473888 VC ONSITE BACKUP HOST SERVER 12,989 12,989
27537123 VALMY 98459139 V1 REVENUE METER, UPGRADE 12,709 12,709 Reliability
Given Idaho Power’s impending exit from Unit 1 operations, it is important to have in place a sufficient measurement infrastructure to properly account for
both owners’ utilization of each unit. Based upon NV Energy’s review of the net megawatt (“MW”) billing infrastructure, it was determined that Valmy lacked
sufficiently accurate meters, totalizers, and communication infrastructure to reliably account for MW generation including transformer losses. At the time
the Company joined the Energy Imbalance Market, the Valmy metering infrastructure had not been upgraded and instead relied on a mix of local readings
from different meters and systems that did not always match. This project consolidates and standardizes Valmy net MW reporting by sending the data to the
plant’s distributed controls system, which then consolidates the information and reports it in a single, consistent value to each owner.
27568580 VALMY 98480883 V2 PULVERIZER 600HP ELECTRIC MOTOR, CAP SPARE 11,641 11,641
27568635 VALMY 98476439 VC FPS DIESEL FIRE PUMP A ENGINE REBUILD 11,605 11,605
27579439 VALMY 98486138 V2 DCS NETWORK GPS TIME SERVER 10,088 10,088
27533147 VALMY 98459448 V1 1ST POINT HEATER EXTRACTION STEAM BLOCK VA 9,119 9,119 Reliability
The block valve that supplies extraction steam to the Unit 1 1st point feedwater heater failed in the closed position in July 2018. This valve serves to isolate
the 1st point feedwater heater from turbine fed extraction steam and also protects the turbine from backflow/water induction by going to closed position
when called on. The failure required the bypass of the 1st point feedwater heater affecting the plant reliability and diminishing the heat rate. This project
refurbished the block valve.
27501116 VALMY 98427786 V1 PULVERIZER "B" MAJOR REBUILD 6,732 6,732 Reliability
Pulverizers are utilized to grind coal to fine dust before being transported to burner fronts. This process wears out roll wheel assemblies, table grinding
segments, and interior of pulverizer equipment. The normal operating life cycle of a Unit 1 pulverizer is roughly 18 to 24 months. Routine inspections are
performed at 3,000 hours and required maintenance is performed to ensure the maximum life of the pulverizer rebuild. Major overhaul includes
replacements of roll wheels, air seals, coal shields, bearings, wear resistant ceramic liners, classifier vanes, coal feeder wear components, spring frame wear
plate, and the pyrites plow. In addition, the gearbox and lubrication system was refurbished and other associated welding and re‐building was performed
due to erosions to the pulverizer housing and associated equipment. The purpose of this project is for the continued reliable operation of Unit 1.
27545750 VALMY 98466598 VC UTILITY CARTS, REPLACE 6,268 6,268
27570624 VALMY 98478541 V2 BOILER DRUM MERLI REPL 2,582 2,582
27517150 VALMY 98442216 ACOUSTIC MONITORING SECU 2,051 2,051
27545747 VALMY 98454282 OT PLANT TECHNICIAN TOOLS NORT 988 988
27502692 VALMY 98434198 V1 SORBENT TRAP MERCURY MONITO 929 929 Environmental
A mercury monitoring system is required for environmental compliance. The monitoring provisions apply to the measurement of total vapor phase mercury
in emissions from sorbent trap monitoring systems that must be capable of measuring mercury in units of the applicable emissions standards. The existing
monitoring system suffered failures requiring parts to be replaced and exhausted warehouse stock. While attempting to replenish the stock, it was
determined that replacement parts were no longer available. This project replaced the existing sorbent trap mercury monitoring equipment with units which
meet compliance requirements and have parts readily available to maintain compliance. The majority of the project costs closed in 2018, with some
remaining dollars closing in 2019.
27502694 VALMY 98434199 V2 SORBENT TRAP MERCURY MONITO 627 627 27587123 VALMY 98490976 VC CONVEYOR 2 GEARBOX 521 521
27590308 VALMY 98493304 V2 CONDENSATE PUMP B MOTOR REPLACEMENT 162 162
27509175 VALMY 98437316 VC RO MEMBRANES, REPLACE 92 92
27514789 VALMY 98443689 V1 ID FAN MOTOR 1B, REBUILD (1,002) (1,002)
27440893 VALMY 98376800 VC PRODUCTION WELL #10 REPLACE (109,095 (109,095
Grand Total 416,860 2,707,651 1,532,927 4,657,437
Exhibit No. 2 Case No. IPC-E-22-05 L. Barretto, IPC
Page 3 of 3
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-22-05
IDAHO POWER COMPANY
BARRETTO
TESTIMONY
CONFIDENTIAL
EXHIBIT NO. 3