20230601Direct Barretto.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC SERVICE IN THE STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY ACCOUNTING TREATMENT.
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CASE NO. IPC-E-23-11

IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
LINDSAY BARRETTO
BARRETTO, DI 1
Idaho Power Company
Q. Please state your name, business address, and 1
present position with Idaho Power Company (“Idaho Power” or 2
“Company”). 3
A. My name is Lindsay Barretto. My business 4
address is 1221 West Idaho Street, Boise, Idaho 83702. 5
Q. Please describe your educational background. 6
A. I received a Bachelor of Science degree in 7
Civil Engineering from Purdue University, West Lafayette, 8
Indiana in 2005. In 2007, I earned a Master of Science 9
degree in Civil Engineering from Purdue University. I am a 10
registered professional engineer in the state of Idaho. 11
Q. Please describe your work experience with 12
Idaho Power. 13
A. I began my employment with Idaho Power in 2010 14
as an engineer in Power Production’s Civil Engineering 15
department. As an engineer I worked on hydroelectric and 16
hatchery projects and regulatory compliance. In 2015, I 17
moved to Transmission and Distribution Engineering and 18
Construction as a project manager leading power line and 19
substation projects. In 2018, I became an Engineering 20
Leader, responsible for the Stations Engineering and Design 21
department. In 2020, I was promoted to my current 22
position, Senior Manager of 500kV and Joint Projects, where 23
my responsibilities include supervision over Idaho Power’s 24
500kV and Joint Projects. 25
BARRETTO, DI 2
Idaho Power Company
Q. What is the purpose of your testimony in this 1
matter? 2
A. My testimony discusses the prudent nature of 3
investments made at the North Valmy Power Plant (“Valmy”) 4
and the Jim Bridger Power Plant (“Bridger”) since the 5
Company’s last prudence determinations before the Idaho 6
Public Utilities Commission (“Commission”), including a 7
discussion of Idaho Power’s compliance with Order No. 8
34349, issued in Case No. IPC-E-22-05, as modified with 9
Order No. 35774. 10
Q. What exhibits are you sponsoring? 11
A. I am sponsoring Exhibit Nos. 1, 2 and 3. 12
I. BACKGROUND 13
Q. Please describe the Bridger and Valmy plants. 14
A. Valmy is a coal-fired power plant that 15
consists of two units and is located near Winnemucca, 16
Nevada. Unit 1 went into service in 1981 and Unit 2 17
followed in 1985. Idaho Power owns 50 percent of Valmy. NV 18
Energy is the co-owner of the plant with the remaining 50 19
percent ownership and operates the Valmy facility. Idaho 20
Power and NV Energy (collectively, the “Valmy Co-Owners”) 21
work jointly to make decisions regarding Valmy. The Company 22
exited coal-fired operations of Unit 1 December 31, 2019, 23
as accepted by the Commission in Order No. 33983 as part of 24
Idaho Power’s 2017 Integrated Resource Plan. The Preferred 25
BARRETTO, DI 3
Idaho Power Company
Portfolio identified in the 2021 IRP, filed in Case No. 1
IPC-E-21-43, concluded an exit from Valmy Unit 2 in 2025 2
provides a more favorable economic outcome when compared to 3
an earlier exit. 4
The Bridger plant, located near Rock Springs, 5
Wyoming, consists of four generating units. PacifiCorp has 6
two-thirds ownership and is the operator of the facility 7
and Idaho Power owns one-third of Bridger. Unit 1 began 8
commercial operation in 1974, Unit 2 in 1975, Unit 3 in 9
1976 and Unit 4 in 1979. The Company and PacifiCorp 10
(collectively, the “Bridger Co-Owners”) work jointly to 11
make decisions regarding the plant, including required 12
investments and the retirement of the plant. Idaho Power’s 13
Second Amended 2019 IRP acknowledged in Case No. IPC-E-19-14
19 identified a preferred portfolio that included early 15
Bridger unit exits in 2022, 2026, 2028, and 2030. 16
Subsequently, the 2021 IRP Preferred Portfolio, filed in 17
Case No. IPC-E-21-43, includes the conversion of Units 1 18
and 2 from coal to natural gas by the summer of 2024, and 19
the exit of coal-fired operations in Units 3 and 4 by year-20
end 2025 and 2028, respectively. 21
Q. What are the current agreements under which 22
the Valmy Co-Owners own and operate the plant? 23
A. The ownership and operation of Valmy is 24
governed by three agreements: the Agreement for the 25
BARRETTO, DI 4
Idaho Power Company
Ownership of the North Valmy Power Plant Project and the 1
Agreement for the Operation of the North Valmy Power Plant 2
Project, both of which are dated December 12, 1978, and the 3
North Valmy Station Operating Procedures Criteria, dated as 4
of February 11, 1993, between Idaho Power Company and 5
Sierra Pacific Power Company,1 as amended by Amendment No. 1 6
to the Operating Procedure Criteria for Valmy Coal 7
Diversion Procedures and Usage, dated as of January 1, 8
2012. Additionally, the Valmy Co-Owners entered into the 9
North Valmy Project Framework Agreement between NV Energy 10
and Idaho Power dated as of February 22, 2019, 11
memorializing the terms and conditions under which either 12
partner may elect exit of participation of Valmy. 13
Q. What agreements govern the ownership and 14
operation of the Bridger plant? 15
A. Currently, the ownership and operation of 16
Bridger is dictated by three agreements: the Agreement for 17
the Ownership of the Jim Bridger Project between Idaho 18
Power Company and Pacific Power & Light Company, the 19
Agreement for the Construction of the Jim Bridger Project 20
between Idaho Power Company and Pacific Power & Light 21
Company, and the Agreement for the Operation of the Jim 22
Bridger Project between Idaho Power Company and Pacific 23

1 Sierra Pacific Power Company has conducted business as NV Energy since 2008.
BARRETTO, DI 5
Idaho Power Company
Power & Light Company, all of which are dated September 22, 1
1969, as amended by Amendments 1 through 9 (collectively, 2
“Bridger Agreements”). The Bridger Agreements set forth the 3
respective obligations of the Bridger Co-Owners with 4
respect to the ownership, construction and operation of 5
Bridger. 6
II. RATEMAKING TREATMENT OF VALMY AND BRIDGER 7
Q. Has the Company requested from the Commission 8
any ratemaking treatment associated with the coal 9
investments in Valmy and Bridger based on the early exit of 10
coal-fired operations? 11
A. Yes. In Case No. IPC-E-16-24 and updated in 12
Case No. IPC-E-19-08, Idaho Power requested approval of a 13
balancing account mechanism designed to smooth revenue 14
requirement impacts associated with the shutdown of Valmy 15
and allow for full recovery of Valmy-related costs near the 16
plant’s end-of-life. In addition, this mechanism more 17
closely aligns the cost recovery period with the remaining 18
operating life of the plant, resulting in a better matching 19
of cost recovery from customers who benefit from the 20
plant’s operations while mitigating the risk of future 21
customers bearing the costs of a plant that will no longer 22
be providing service. The Commission approved the Company’s 23
request with Order Nos. 33771 and 34349, respectively. 24
Similarly, in Case No. IPC-E-21-17, Idaho Power requested 25
BARRETTO, DI 6
Idaho Power Company
approval of a balancing account mechanism for the Bridger 1
coal-related investments, which was approved by the 2
Commission with Order No. 35423. 3
Q. Did approval of the balancing account 4
mechanisms for both plants include a prudence determination 5
of the investments at the time? 6
A. Yes. With the issuance of Order No. 34349, it 7
was determined that all Valmy investments through December 8
31, 2018, had been prudently incurred. Further, in Case No. 9
IPC-E-22-05, the Company requested the Commission find that 10
all actual Valmy investments made during the January 1, 11
2019, through December 31, 2021, time period were prudently 12
incurred. However, Order No. 34349, issued in Case No. IPC-13
E-22-05 delayed a prudence determination of Valmy 14
investments. With respect to Bridger, Order No. 35423 found 15
that all Bridger coal-related investments through December 16
31, 2020, were prudently incurred. 17
Q. Why did the Commission delay a prudence 18
determination on the Valmy investments made during the 19
January 1, 2019, through December 31, 2021, time period? 20
A. In their review of Idaho Power’s request, 21
Commission Staff (“Staff”) analyzed two types of prudence, 22
decisional prudence, which is based on need, and 23
operational prudence, which is based on whether or not the 24
Company implemented the investment in the least-cost 25
BARRETTO, DI 7
Idaho Power Company
manner. Commission Staff concluded that the investments 1
were needed to continue safe and reliable operation of the 2
facility, or decisional prudence, but indicated they could 3
not “recommend that the investments were operationally 4
prudent due to lack of sufficient evidence documenting that 5
the projects were done in a least-cost way.”2 As such, 6
Staff recommended Idaho Power work with them to develop the 7
documentation necessary for Commission Staff’s audit and 8
prudence review and provide Commission Staff with the 9
additional information via a compliance filing within six 10
months of the Commission’s order to determine prudence.3 11
With Order No. 35494, the Commission indicated it was “fair 12
just and reasonable for the Company to file additional 13
documentation to support a prudence determination as part 14
of the 2022 Annual Review” after working with Commission 15
Staff to expand the documentation process.4 16
Q. Did Idaho Power file additional documentation 17
to support a prudence determination as part of the Valmy 18
2022 Annual Review? 19
A. No. On March 31, 2023, after discussing with 20
Staff, Idaho Power filed a Motion for an Extension of Time 21
to Comply with Order No. 35494 because Commission Staff and 22
the Company were still working to memorialize and finalize 23

2 Case No. IPC-E-22-05, Staff Comments, p. 4.
3 Id. At 8.
4 Order No. 34594 at 6.
BARRETTO, DI 8
Idaho Power Company
the information and documentation necessary for Commission 1
Staff’s prudence review. As part of this Motion, Idaho 2
Power proposed to include the request for a prudence 3
determination and the associated documentation, as part of 4
this general rate case proceeding. The Motion requested the 5
Commission acknowledge the Company will include its 2022 6
Annual Review, as required by Order No. 34349, as part of 7
the general rate case filing as well. The Commission issued 8
Order No. 35774 on May 8, 2023, granting the Motion. 9
Q. Have Idaho Power and Staff come to an 10
agreement regarding an expanded documentation process for 11
investments made at the Company’s jointly-owned generating 12
facilities? 13
A. Yes, in principle. However, Staff and Idaho 14
Power are still working to finalize a Memorandum of 15
Understanding (“MOU”) that will govern Idaho Power’s 16
demonstration of oversight of its jointly-owned generating 17
facilities, and will represent a mutual agreement on the 18
types of information the Company will file to support its 19
request for a prudence determination of expenditures made 20
at the Valmy and Bridger plants. Staff and Idaho Power are 21
finalizing a Major Projects Checklist that is intended to 22
detail the review timing and documentation to accompany 23
capital project expenditures over a certain dollar 24
threshold, and an Oversight Meeting Checklist that will 25
BARRETTO, DI 9
Idaho Power Company
document Idaho Power’s ongoing and continual participation 1
in the capital budget reviews of each plant throughout the 2
year, encompassing the entirety of the capital budget 3
regardless of the dollar amount of individual projects. A 4
summary of the key provisions envisioned to be contained in 5
an MOU is provided as Exhibit No. 1 to my testimony. 6
Q. Based on the Company’s request for a prudence 7
determination of the Valmy and Bridger investments in this 8
proceeding, has the Company prepared the documentation 9
necessary to support the investments? 10
A. Yes, Idaho Power has the documentation 11
necessary to support a prudence determination of the Valmy 12
and Bridger investments. However, the Company cannot 13
retroactively complete checklists for meetings that have 14
already occurred, but Idaho Power stands ready to provide 15
all available information for the Valmy and Bridger capital 16
projects in support of a prudence determination. 17
III. VALMY INVESTMENTS SINCE 2018 18
Q. As a 50-percent owner in the plant, is Idaho 19
Power involved in the decision-making process related to 20
capital investments at Valmy? 21
A. Yes. As the plant operator, NV Energy manages 22
the capital budget for Valmy. However, Idaho Power has 23
established guidelines at Valmy to allow NV Energy to 24
manage the capital budget as needed and directed by the 25
BARRETTO, DI 10
Idaho Power Company
plant manager, without exceeding the yearly budget, or 1
adding large projects without authorization by the Valmy 2
Co-Owners. These guidelines provide the appropriate level 3
of oversight while allowing the plant operator to 4
practically manage the plant and any variances that may 5
occur throughout the budget year. 6
Q. What guidelines are in place to monitor 7
capital expenditures at Valmy? 8
A. First, if Idaho Power’s share of the capital 9
forecast is greater than the capital budget by more than 10
$100,000, the Company will review and may authorize the 11
budget change. In addition, all new or unbudgeted Unit 2 12
or common facility capital projects larger than $1 million, 13
at the plant level, require a review and authorization in 14
writing by each Valmy Co-Owner prior to starting the 15
project. Finally, any time an individual Unit 2 or common 16
facility capital project with a value greater than $1 17
million, at the plant level, is forecast to exceed the 18
current year original budget by 20 percent, each Valmy Co-19
Owner must review and authorize it in writing prior to 20
starting or continuing the project. 21
Q. Aside from the guidelines, are there any other 22
ways the Company participates in the capital budget 23
process? 24
BARRETTO, DI 11
Idaho Power Company
A. Yes. Individual capital project variances are 1
discussed during Ownership Meetings and other meetings as 2
directed by the Valmy Co-Owners. In addition, NV Energy 3
produces an Authorization for Expenditures (“AFE”) request 4
for all capital projects. AFEs include the project title, 5
date, project manager, description and purpose of the 6
expenditure, cost and budget information, along with 7
various other information to provide support for the 8
project. If the project is expected to exceed the AFE 9
amount by either 10 percent, for variances greater than 10
$10,000, or $100,000, a supplemental AFE is required. 11
Currently, Idaho Power provides authorization to NV 12
Energy of all AFEs and supplemental AFEs for each project. 13
The Company has requested that no projects begin, and the 14
total annual budget may not be exceeded, unless the AFE is 15
approved by both NV Energy and Idaho Power. Lastly, in 16
addition to the plant-specific guidelines detailed above, 17
Idaho Power performs holistic budget reviews on a monthly 18
and quarterly basis. This includes capital expenditures at 19
all of the Company’s facilities, including Valmy, and 20
therefore provides an additional review process through 21
which the Company monitors its capital spend at Valmy. 22
Q. What is the time period for which Idaho Power 23
is requesting a prudence determination of Valmy 24
investments? 25
BARRETTO, DI 12
Idaho Power Company
A. Because Order No. 34349 delayed a prudence 1
determination on the Valmy investments made during the 2
January 1, 2019, through December 31, 2021, time period, 3
the Company is requesting a prudence determination of Valmy 4
investments made during the January 1, 2019, through 5
December 31, 2022, time period. There have been a number of 6
investments required to operate the plant in a safe, 7
efficient, and reliable manner, including investments 8
required to ensure environmental compliance as well as a 9
number of investments for routine asset replacement. 10
Exhibit No. 2 presents Idaho Power’s share of the 11
investments made at Valmy between January 1, 2019, and 12
December 31, 2022, detailing 92 different capital projects 13
totaling $8.19 million. In addition, for those projects for 14
which Idaho Power’s ownership share is over $50,000, and 15
all investments associated with Unit 1, the Company has 16
included a project description and investment purpose 17
classification as to whether the investment was for 18
environmental compliance, safety, and/or reliability. Of 19
the 44 projects for which a detailed project description 20
and investment purpose classification was provided, 26 were 21
for continued reliable plant operations, three were 22
required for environmental compliance, and 15 were for a 23
combination of either reliability, environmental 24
compliance, or safety. 25
BARRETTO, DI 13
Idaho Power Company
Q. Why did the Company include a project 1
description and investment purpose classification for all 2
investments associated with Unit 1, even if they were less 3
than $50,000? 4
A. Idaho Power included a project description and 5
investment purpose classification for all investments 6
associated with Unit 1 to highlight that although the 7
Company exited operations of Unit 1 on December 31, 2019, 8
there were investments required to ensure reliable 9
operations of Unit 1 until the Company’s exited 10
participation in coal-fired operations. 11
Q. Were all the projects comprising the $8.19 12
million in investments that occurred between January 1, 13
2019, and December 31, 2022, necessary for either 14
environmental compliance, the safe and economic operation 15
of the plant, or for reliability purposes? 16
A. Yes. 17
Plant Reliability Investments 18
Q. You indicated there were 26 investments 19
greater than $50,000 or associated with Unit 1 that were 20
required for the reliable operation of the plant. What was 21
the largest investment made to maintain reliability? 22
A. While not the largest investment made during 23
the January 1, 2019, through December 31, 2022, time 24
period, the largest investment made solely for reliability 25
BARRETTO, DI 14
Idaho Power Company
purposes was for approximately $630,000 for an update to 1
the Distributed Control System (“DCS”) of Unit 2. 2
Q. Why was an update to the DCS required? 3
A. The existing DCS was installed in 2015 and was 4
operating both servers and human machine interfaces of Unit 5
2. A typical life-cycle of the DCS is 10 years, with a 6
five-year mid-cycle human machine interface and operating 7
system update required. The existing DCS was operating 8
beyond the original equipment manufacturer (“OEM”) support 9
and security patches were no longer being created for the 10
systems. In addition, the control servers were operating on 11
Windows Server 2008, which Microsoft ceased supporting as 12
of January 1, 2020, and the human machine interfaces were 13
operating on Windows 7, which Microsoft stopped supporting 14
as of January 14, 2020. Operating without the OEM supported 15
cybersecurity patches put these servers and human machine 16
interfaces at an elevated security risk. 17
Q. What did the upgrade entail? 18
A. The upgrade replaced the human machine 19
interfaced hardware and upgraded the operating system to 20
Windows 10. In addition, the following control equipment 21
was upgraded: (1) new virtualized Windows 2019 control 22
servers host, (2) Emerson Ovation software, and (3) new 23
ethernet switches and routers. All of the upgrades enabled 24
implementation of the latest critical security controls for 25
BARRETTO, DI 15
Idaho Power Company
cyber defense and detection tools. 1
Q. Were there any additional factors that 2
influenced the decision to update the DCS when the plant 3
did? 4
A. Yes. An additional concern existed with the 5
scheduled retirement of Unit 1. Several common plant 6
systems were controlled by the DCS on Unit 1 and required 7
code changes to move these controls to the DCS on Unit 2. 8
Therefore, the decision was made to upgrade Unit 2’s DCS 9
prior to the retirement of Unit 1 and coincident to other 10
cybersecurity project upgrades. 11
Q. What additional investments were made at Valmy 12
solely for reliability purposes? 13
A. The majority of the investments made to 14
maintain reliable operations of Valmy were associated with 15
normal wear and tear of existing investments which I will 16
discuss first, including (1) the replacement of the 17
pulverizer gear box, (2) the purchase of pulverizer spare 18
parts, (3) the Unit 2 pin mixer replacement, and (4) Unit 2 19
generator bushing gasket replacements. 20
Q. What is the purpose of a pulverizer? 21
A. Pulverizers are utilized to grind coal to fine 22
dust via roll wheel assemblies and table grinding segments 23
before being transported to burner fronts. Each Valmy unit 24
requires four pulverizers to reach full load status each 25
BARRETTO, DI 16
Idaho Power Company
year in order to perform annual testing and certification 1
of the cold reheat safety valves in compliance with the 2
Annual State of Nevada Boiler Operating Permit. The plant 3
maintains a spare pulverizer for Unit 2 in the event of a 4
failure of one pulverizer to maintain reliability. 5
Q. What occurred to require the replacement of a 6
pulverizer gear box? 7
A. One of the pulverizers on Unit 2 tripped, 8
compromising the reliability of the unit. Plant personnel 9
opened the gearbox inspection port and discovered the 10
gearbox had failed. Approximately $588,000 was invested in 11
pulverizer repairs to ensure Unit 2 maintained reliability. 12
Q. Why does the plant purchase spare parts for 13
the pulverizers? 14
A. The grinding of coal to a fine dust wears out 15
the roll wheel assemblies, table grinding segments, and the 16
interior of pulverizer equipment. As a result, the normal 17
operating life cycle of a Unit 2 pulverizer is roughly 18 18
to 24 months until a major rebuild of the pulverizer is 19
required. Routine inspections are typically performed at 20
3,000 hours and maintenance performed to ensure the maximum 21
life of the pulverizer rebuild. However, with an upcoming 22
end-of-life of Unit 2 in 2025, upon routine inspection, it 23
was determined the pulverizers were not in need of a major 24
overhaul. Rather a more cost-effective approach would be to 25
BARRETTO, DI 17
Idaho Power Company
purchase a full set of grinding table segments and three 1
roll wheel assemblies, to expedite repair once excessive 2
wear occurred, while also avoiding long lead times for 3
replacement equipment. In addition, during routine 4
maintenance of a pulverizer at a different time, three 5
refurbished trunnion wheel assemblies were purchased as 6
capital spares, totaling $456,000 and $166,000, 7
respectively, as opposed to performing a major overhaul. 8
The capital spares will allow the capital maintenance 9
outages to be completed on an as needed basis, as opposed 10
to during the routine inspection, when the pulverizers’ 11
hours of operation and level of wear justifies the 12
overhauls. 13
Support of the need for spare pulverizer parts 14
occurred when the Unit 2B pulverizer failed due to a seized 15
roll wheel assembly, compromising reliability. A spare roll 16
wheel assembly was installed at the time, for approximately 17
$231,000, ensuring Unit 2 was in compliance with the State 18
of Nevada testing requirements. Further, in 2019, on the 19
Unit 1D pulverizer, three of the roll wheel assemblies 20
failed, one in April, and two in September requiring 21
replacement, for investments totaling approximately 22
$160,000 and $47,000, respectively. The Unit 1D pulverizer 23
had exceeded 20,000 hours of operation with significant 24
wear and parts deteriorated beyond the service life 25
BARRETTO, DI 18
Idaho Power Company
expectations. Upon inspection, it was found that one of the 1
three wheel assemblies in the pulverizer was cracked and 2
not rotating freely due to a bearing failure. 3
Q. Why was the replacement necessary in 2019 if 4
the Company was exiting the unit that year? 5
A. The plant was coming up on its annual testing 6
and certification of the cold reheat safety valves, a 7
compliance requirement of the annual State of Nevada Boiler 8
Operating Permit as I mentioned earlier, and needed to 9
reach full load status, requiring all four pulverizers. Due 10
to the wear, there were sizing differences of the three 11
roll wheels’ diameters, requiring the replacement of three 12
of the roll wheel assemblies on the Unit 1D pulverizer. 13
Q. What was the purpose of the last two projects 14
resulting from the normal wear and tear of existing 15
investments, the Unit 2 pin mixer replacement and the Unit 16
2 generator bushing gasket replacements? 17
A. The Unit 2 pin mixer, which unloads the wet 18
fly ash, required replacement and was rebuilt prior to the 19
summer run to avoid the potential of a serious failure due 20
to the lack of non-redundant equipment. This project 21
totaled approximately $225,000. In addition, approximately 22
$107,000 was spent to replace bushing gaskets and for the 23
regasketing of the bushing terminal plant. 24
Q. Why must bushing gaskets be replaced? 25
BARRETTO, DI 19
Idaho Power Company
A. The terminal plate gaskets for the high 1
voltage bushings of the generator were worn out and there 2
was indication of bushing gaskets leaking as the viscasil 3
lubricant was seeping through the bushing gaskets, 4
indicating possible failure of the bushing. Bushing gasket 5
leakage could lead to catastrophic failure of the 6
generator. 7
Q. When was this issue first identified? 8
A. The issue was first identified in 2010 and 9
temporary repairs were made. In 2017, it was noticed that 10
the leak had become significant and one more temporary 11
repair was made and annual inspections conducted. However, 12
the 2018 annual inspection discovered more leakage so the 13
replacement of the bushings and regasketing of the bushing 14
terminal plate was performed. 15
Q. What additional investments were made at 16
Valmy to maintain reliability? 17
A. The following investments greater than 18
$50,000 or associated with Unit 1 that were required for 19
the reliable operation of the plant include the (1) 20
installation of freeze protection heaters, (2) repair of 21
the generator exciter power supply system, (3) replacement 22
of the underground equipment wash piping, and (4) recoating 23
of the condenser inlet tube sheet. 24
Q. What necessitated installation of freeze 25
BARRETTO, DI 20
Idaho Power Company
protection heaters? 1
A. In 2018, because the Valmy operating schedule 2
shifted to running the units in only the summer months and 3
to be in long-term layup during the remaining months of the 4
year, it was determined that with both units offline there 5
was no auxiliary steam to provide heat to the turbines, 6
boilers and buildings to keep them dry and above the dew 7
point, per the long-term layup plan. 8
Q. How was Valmy heated at the time? 9
A. The plant was renting portable electric space 10
heaters to sufficiently heat the plant buildings and 11
equipment during the layup period. However, it was 12
determined that the purchase of the heaters for 13
approximately $541,000 was more cost-effective than 14
renting. In addition, the purchase and installation 15
included four water-to-air dry finned coolers which cool 16
the component cooling system on each unit and exhaust warm 17
dry air into the lower level of the turbine building, 18
reducing the number of electric heaters required to be 19
purchased. Heating of the turbines and buildings helps 20
ensure the units can be operational when needed. 21
Q. What occurred that required the replacement of 22
the generator current transformers? 23
A. The Unit 2 exciter power supply transformers 24
had failed, preventing the unit from returning to service. 25
BARRETTO, DI 21
Idaho Power Company
One of the three saturable current transformers that supply 1
power to the generator exciter, one linear reactor 2
transformer, and the exciter control card module were 3
damaged. This project, which totaled approximately 4
$468,000, replaced two saturable current transformers that 5
had compromised integrity due to oil and heat damage as 6
well as one of the remaining linear reactor transformers 7
that had degraded while running at an elevated temperature. 8
Q. What was the replacement of the underground 9
equipment wash piping necessary to maintain reliability of 10
Valmy? 11
A. A section of the boiler equipment wash piping, 12
which is used to fill both circulating water systems prior 13
to start-up, failed. The underground piping was the 14
original piping put in during construction in 1979. Using 15
alternative means to fill the circulating water systems is 16
very time consuming and results in start-up delays, thus 17
requiring the replacement of the underground equipment wash 18
piping. The replacement of the boiler equipment wash piping 19
in 2021 was approximately $151,000. 20
Q. Why was recoating of the condenser inlet tube 21
sheet necessary to maintain reliability at Valmy? 22
A. In 2019, the recoating of the condenser inlet 23
tube sheet was required contributing to approximately 24
$108,000 of the Valmy investments. The condenser inlet 25
BARRETTO, DI 22
Idaho Power Company
tube sheet of a unit is exposed to erosion from particles 1
and turbulence in the circulating water. It is coated with 2
a wear resistant coating to protect the metal tube sheet 3
and condenser tube ends. The coating on Unit 2 had worn to 4
the point that significant portions of bare tube and tube 5
ends were exposed. 6
Q. What happens if the metal tube sheet and 7
condenser tub ends are left exposed? 8
A. When exposed, the tube ends will erode and can 9
result in tube failure and leakage of circulated water into 10
the steam side of the condenser, contaminating the boiler 11
water. Recoating of the tube sheet was required. However, 12
when the recoating began, the plant was able to repair some 13
of the existing waterbox coating resulting in project costs 14
lower than initially estimated. 15
Q. What additional investments were made solely 16
for reliability purposes? 17
A. The remaining 13 projects associated with 18
investments for reliable operations of Valmy made between 19
the January 1, 2019, through December 31, 2022, time period 20
that I have not discussed yet were all between $50,000 and 21
$100,000. They included: (1) the refurbishment of the Unit 22
2 boiler feed pump, (2) the replacement of the coal 23
handling conveyor following sustained run time failure, (3) 24
the replacement of the pumps on production wells 13 and 14, 25
BARRETTO, DI 23
Idaho Power Company
(4) the purchase and installation of two redundant 1000 1
kilovolt-amp transformers that power the coal handling 2
system following failure beyond economic repair, (5 and 6) 3
two projects associated with the motor of the Unit 1 4
circulating water pump that failed following a ground 5
fault, one investment associated with the replacement of 6
the motor and the second with the rewind of the failed 7
motor for use as a capital spare, (7) the use of a capital 8
spare to replace the failed Unit 2A pulverizer, (8) the 9
replacement of three generator current transformers 10
following failure, (9) the installation of the spare Unit 11
1A primary air fan motor due to damage, (10) a new fly ash 12
blower to convey ash in order to prevent the baghouse 13
hoppers from overflowing due to internal wear and damage, 14
(11) an upgrade of the revenue meter required when Idaho 15
Power exited participation in operations of Unit 1, (12) 16
refurbishment of the block valve that supplies extraction 17
steam to the Unit 1 first point feedwater heater, and (13) 18
the Unit 1B pulverizer rebuild. Exhibit No. 2 provides 19
additional information for each project including the total 20
investment amount and a detailed project description and 21
justification. 22
Q. How have these 26 investments required for the 23
continued reliable operations of Valmy contributed to the 24
additions at the plant since January 1, 2019? 25
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Idaho Power Company
A. At $4.50 million, the investments for 1
reliability purposes are the largest expenditures made at 2
Valmy since 2018, making up 55 percent of the total 3
projects. 4
Q. You mentioned some of the investments over 5
$50,000 or associated with Unit 1 were made for a 6
combination of either reliability, environmental 7
compliance, or safety purposes. Were there any additional 8
investments for which the purpose included a reliability 9
component? 10
A. Yes. There were eight projects required for a 11
combination of reliability and safety purposes. 12
Plant Reliability and Safety Investments 13
Q. Please describe those projects greater than 14
$50,000 or associated with Unit 1 that have been identified 15
as required for reliability and safety purposes. 16
A. The largest investment made at Valmy during 17
the January 1, 2019, through December 31, 2022, time period 18
was for a combination of reliability and safety purposes. 19
In 2021, $1.24 million was spent to fix the Unit 2 turbine 20
high pressure/intermediate pressure (“HP/IP”) section shell 21
steam leaks. 22
Q. What caused the HP/IP section shell steam 23
leaks on the Unit 2 turbine? 24
A. Beginning in 2015, the Unit 2 steam turbine 25
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HP/IP shell experienced five steam leaks from the mating 1
surfaces of the steam turbine HP/IP upper and lower shells. 2
Each steam leak damaged the two turbine shells by eroding 3
the mating surfaces material and providing further paths 4
for the superheated steam to escape from the turbine HP/IP 5
shells. At the time, previous repairs did not fix the 6
eroded mating surfaces or the compromised connection 7
hardware that compresses the two shell halves together to 8
form the mating surfaces seal. 9
Q. What happens when the mating surfaces and 10
connection hardware is not repaired? 11
A. Connecting hardware eventually wears out, only 12
enduring a limited number of tightening and loosening 13
cycles before the connecting hardware loses its strength 14
and the ability to provide the compressive forces necessary 15
to form the mating surfaces seal of the two shell halves. 16
This loss of connecting hardware strength is also 17
compounded by the high temperature during operations 18
causing the plastic deformation of the steel. This process 19
is known as creep. 20
Q. How did the creeping compound the issues with 21
the HP/IP shells? 22
A. The plastic deformation, in conjunction with 23
applied stresses, can also warp and distort both the 24
connecting hardware and the HP/IP shells themselves. A 25
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Idaho Power Company
‘tapped stud’ threads into the lower shell half and a large 1
nut is installed on the upper portion of the tapped stud 2
and tightened to apply the compressive force to the two 3
shell mating surfaces. 4
Q. Were the tapped studs of the HP/IP shells 5
affected? 6
A. Yes. A minimum of six tapped connecting studs 7
are known to have been compromised in some fashion, mostly 8
warpage. 9
Q. What was the extent of the investments 10
necessary to repair and prevent future HP/IP section shell 11
steam leaks? 12
A. This project replaced the connecting hardware, 13
which was no longer providing sufficient consistent 14
compressive force, with new hardware and refurbished the 15
mating surfaces of the two HP/IP shells. The two turbine 16
HP/IP turbine shells were separated, and the mating 17
surfaces were refurbished with a combination of welding and 18
machining. In addition, ten tapped connecting studs and 19
nuts on each side of the HP/IP turbine section in the areas 20
of the five steam leaks were replaced with new tapped 21
connecting studs and nuts. The tapped stud threads in the 22
lower half shell were also repaired as necessary. The 23
tapped studs replacement, lower half thread repairs and 24
HP/IP shell mating surfaces refurbishment were made after 25
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the two HP/IP shells were separated. These repairs 1
corrected the known root causes and corrected for the 2
turbine HP/IP section shell steam leaks. 3
Q. What additional investments required for both 4
safety and reliability purposes were made? 5
A. In November 2017 an evaluation of the fire 6
protection systems was performed that determined the 7
refurbishment or replacement of the systems was required 8
due to degradation of the existing system, through a 9
combination of worn out and/or outdated components and 10
systems. As a result, the refurbishment of the Early 11
Warning Smoke Detection system was performed, the Unit 1 12
and Unit 2 stand-pipe booster pipes were replaced, the fire 13
alarm control panels and associated controls and alarms 14
were replaced, the deluge valves were replaced, and the 15
required flow testing of the electric fire pump and the 16
diesel fuel tank system was performed. Total project costs 17
were approximately $263,000. 18
In addition, Unit 2 was experiencing erratic control 19
valve movement that resulted in unit trips due to the 20
resulting load and drum level swings. The primary cause of 21
the erratic valve movement was leakage in the upper and 22
lower positioners. To operate as reliably as possible and 23
limit the erratic valve movements, the control valves were 24
kept wide open. Replacement of the upper and lower turbine 25
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Idaho Power Company
control valve hydraulic cylinder positioners, for 1
approximately $119,000, was necessary to restore stable 2
operation of the turbine and improve plant reliability. 3
Q. Please describe the additional investments 4
made between January 1, 2019, and December 31, 2022, 5
classified as required for reliability and safety purposes. 6
A. The next set of investments over $50,000 or 7
associated with Unit 1 made for reliable and safe operation 8
of the plant were required because of the age of the 9
existing investment and the associated wear and tear, 10
including the replacement of the Unit 2 stack elevator and 11
transportation fleet at the plant. The stack elevator was 12
installed with Unit 2 in 1984 and replacement parts had 13
become obsolete. On several occasions the elevator stopped 14
operating properly during the installation of environmental 15
compliance equipment and prior to scheduled emission 16
testing, causing delayed installation timelines. A total 17
of approximately $107,000 was invested to complete the 18
elevator replacement including the car, brake assembly, 19
drive motor and gearbox, electrical system replacement and 20
call system replacement. 21
In 2020 and 2022, approximately $88,000 and $78,000, 22
respectively, was spent to replace some of the van 23
transportation fleet due to concern with safety and 24
reliability. The Valmy fleet was aging and reaching high 25
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Idaho Power Company
mileage, traveling approximately 1,750 miles for 1
maintenance and 5,200 miles for operations/fuels per month 2
by 2022. The vans transport employees to and from the 3
remote plant site, 24 hours a day, seven days a week, which 4
is a standard in northern Nevada set by local mining 5
companies. Three of the existing nine vans were replaced 6
in both 2020 and again in 2022 as each van was over ten 7
years old with between 190,000 to 256,000 miles. 8
Q. What were the two remaining investments made 9
for reliability and safety purposes between January 1, 10
2019, and December 31, 2022? 11
A. The remaining investments identified as 12
necessary for reliable and safe operations of Valmy include 13
the (1) refurbishment of the trisector air heater expansion 14
joint following damage from thermal expansion, rust, acid 15
condensation and erosion, and (2) refurbishment of the 16
first point feedwater inlet valve on Unit 1. 17
Q. How have these projects, necessary for the 18
continued reliable and safe operations of Valmy, 19
contributed to the additions at the plant since January 1, 20
2019? 21
A. The investments made at Valmy for reliability 22
and safety purposes during the January 1, 2019, through 23
December 31, 2022, time period total $1.97 million, or 24 24
percent of the total projects. 25
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Q. Were there any additional investments made at 1
Valmy between January 1, 2019, and December 31, 2022, that 2
included a purpose classification for continued reliable 3
operations of the plant? 4
A. Yes. There were five projects associated with 5
continued reliable operations of Valmy as well as required 6
for environmental compliance. 7
Plant Reliability and Environmental Compliance Investments 8
Q. What were the Valmy investments required for 9
continued reliable operations and environmental compliance 10
purposes? 11
A. Four of the investments made at Valmy between 12
January 1, 2019, and December 31, 2022, and identified as 13
required for both continued reliable operations and 14
environmental compliance were associated with the scrubber 15
atomizer wheels on Unit 2, while the largest investment 16
made was associated with the scrubber spray machine gearbox 17
that drives the atomizer wheels. The dry scrubber on Unit 2 18
utilizes nine atomizing spray machines, three atomizers per 19
scrubber vessel, to atomize a lime/recycled fly ash mixed 20
slurry that reacts with the sulfur dioxide in the flue gas 21
to produce calcium sulfate. The solid calcium sulfate 22
particles are then collected along with fly ash in the 23
baghouse. 24
To accomplish this, the atomizer wheel rotates via 25
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Idaho Power Company
the gearbox at approximately 13,000 revolutions per minute 1
and centrifugal force shears the lime/recycled ash slurry 2
into very small droplets for intimate liquid/gas contact. 3
The force of the shearing slurry slowly erodes the atomizer 4
wheels which require routine replacement. An atomizer wheel 5
can be expected to last for 10,000 to 12,000 hours in 6
service. In 2019 the procurement of six new atomizer 7
wheels was required. Five of the atomizer wheels that were 8
at the end of their service life were replaced in 2020 and 9
2021, and eight were replaced in 2022. In addition, the 10
gearbox, which requires precision balancing and tight 11
tolerance on gear clearances could not be repaired and 12
required replacement. The five projects totaling 13
approximately $683,000 were required to ensure the 14
continued reliable operations of Valmy. 15
Environmental Compliance Investments 16
Q. What investments were made at Valmy solely for 17
environmental compliance? 18
A. There were three investments over $50,000 or 19
associated with Unit 1 made at Valmy between January 1, 20
2019, and December 31, 2022, for which the purpose was 21
environmental compliance. The first, for approximately 22
$220,000, included the installation of nine new ground 23
water monitoring wells. 24
Q. Why were the new ground water monitoring wells 25
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required? 1
A. Ground water elevation at Valmy had risen 2
noticeably over the last six to eight years, presumably due 3
to cessation of dewatering activities at the nearby Lone 4
Tree Mine. As a result, the screened interval intake of 5
several wells was nearly fully submerged. 6
Q. Are there guidelines in place for appropriate 7
groundwater levels? 8
A. Yes. According to Nevada Division of 9
Environmental Protection (“NDEP”) monitoring well 10
guidelines, the groundwater level should be within the 11
screened interval level to obtain an accurate water level 12
reading. Any reported ground water levels above the top 13
screen level are considered invalid. At the time, of the 14
Valmy plant’s 14 ground water monitoring wells, five were 15
reading above the top screen level and four were close. 16
Q. What would happen if the groundwater levels 17
were not addressed? 18
A. If the wells were not redrilled, plugged, 19
abandoned or replaced, the existing wells may have become 20
non-compliant with the regulatory intent of monitoring the 21
potential impacts of operating the facilities’ landfill and 22
evaporation ponds. In addition, if not in compliance, the 23
NDEP can order similar action. As a result, the plant 24
installed nine new ground water monitoring wells. 25
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Idaho Power Company
Q. Please describe the remaining investments made 1
at Valmy for environmental compliance. 2
A. Approximately $13,000 was associated with the 3
replacement of the low nitrogen-oxide burner nozzles of 4
Unit 1 to remain compliant with the Mercury and Air Toxics 5
Standards, and finally $1,000 of costs were associated with 6
the replacement of the existing sorbent trap mercury 7
monitoring equipment closed in 2019. 8
Q. Were there any additional investments made at 9
Valmy between January 1, 2019, and December 31, 2022, that 10
included a purpose classification for environmental 11
compliance? 12
A. Yes. There were two projects over $50,000 or 13
associated with Unit 1 that were required for both 14
environmental compliance and the continued safe operations 15
of Valmy. 16
Environmental Compliance and Safety Investments 17
Q. Please describe the first required investment 18
for environmental compliance and safety. 19
A. The three dry scrubber vessels on Unit 2 often 20
suffer severe scaling and/or debris material buildup as 21
scale is dislodged from the scrubber vessel walls. The 22
scale and buildup can be severe enough that several times 23
per year the unit is curtailed by 70 MWs while the scale 24
and buildup are removed from the vessel walls and the 25
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Idaho Power Company
outlet duct via the existing debris chute and from the 1
outlet duct door. The debris material is then collected and 2
transported to the ash landfill. The removal of the debris 3
is required under the Mercury and Air Toxic Standards 4
regulations. 5
In 2020, approximately $127,000 in project costs 6
were incurred to enlarge the existing Unit 2 scrubber 7
vessel debris chute and install three 24-inch diameter 8
hydraulically actuated knife gate valves. The purpose was 9
to allow for the faster and safer removal and collection of 10
the scale, sludge and debris for disposal in the ash 11
landfill. The investment reduced the duration of forced 12
outages by 50 percent. In addition, automation of the 13
valves to open the scrubber vessel, which previously 14
required personnel to perform via a ladder, rectified a 15
safety concern. 16
Q. What additional investment was made for 17
environmental compliance and safety of Valmy? 18
A. The primary and backup scrubber computer room 19
air conditioning units were aging equipment and required 20
frequent maintenance. Operating failures of the system had 21
resulted in unit trips due to overheating of the baghouse 22
pollution control device that is located in the scrubber 23
computer room. Baghouse pollution control device components 24
and the HVAC units were repaired and returned to service, 25
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Idaho Power Company
but overheating was a recurring problem. Replacement of 1
both the primary and backup scrubber computer room air 2
conditioning units totaling approximately $65,000 was 3
necessary to ensure reliable operation of Unit 2 while also 4
maintaining safety of the plant personnel. 5
Q. Please summarize the investments that were 6
made at Valmy over $50,000 or were specific to Unit 1 that 7
make up the $8.19 million for which Idaho Power is 8
requesting a prudence determination. 9
A. Of the 44 projects for which a detailed 10
project description and investment purpose classification 11
was provided, 26 were for the continued reliable plant 12
operations totaling $4.50 million, another $234,000 was 13
associated with the three projects required for 14
environmental compliance, and the remaining 15, which were 15
for the combination of either reliability, environmental 16
compliance, or safety, contributed to $2.85 million of the 17
total investments made at Valmy between January 1, 2019, 18
through December 31, 2022. 19
IV. BRIDGER INVESTMENTS SINCE 2020 20
Q. As a one-third owner in the plant, is Idaho 21
Power involved in the decision-making process related to 22
capital investments at Bridger? 23
A. Yes. As the plant operator, PacifiCorp 24
manages the capital budget for Bridger. However, the 25
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Idaho Power Company
Company is and always has been actively involved in the 1
decision-making process in all matters associated with 2
Bridger capital investments as a co-owner. While 3
PacifiCorp, as the operator, vets and analyzes the need for 4
specific capital replacements as they arise to continue 5
reliable and safe operation of the plant, Idaho Power 6
regularly participates in discussions of the capital 7
investment forecast prepared by PacifiCorp, influencing the 8
investments ultimately made. 9
Q. What documentation does the Company review 10
as the one-third owner and non-operating partner? 11
A. Idaho Power receives from PacifiCorp a 12
monthly billing invoice, invoice support documentation, and 13
monthly invoice reconciliation. Appropriation Requests are 14
available for every project, which include a project 15
description, investment reason, project number, and 16
projected expenditures for the project, by year. During the 17
quarterly Ownership Meetings, Idaho Power reviews the 18
current year operations and maintenance (“O&M”) expense and 19
capital budgets and forecasts. As noted in the Exhibit No. 20
1, Idaho Power plans to implement an Oversight Meeting 21
Checklist to document its participation in these quarterly 22
meetings at Bridger, including the budget overview document 23
provided at and discussed during these meetings. 24
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Q. Does Idaho Power have any contractual rights 1
to approve items such as capital spend? 2
A. Yes. Under Section 5.4 of the Operation 3
Agreement, each October PacifiCorp will submit a forecast 4
of its estimate of operating expenses for the following 5
calendar year, including capital projects, to Idaho Power. 6
The budget will include items of expenditures for 7
replacement and repair of facilities and will include a 8
contingency for emergency repairs and replacements. The 9
forecast is subject to approval by the Company. Under the 10
agreement, if the forecast for projects changes by 10 11
percent or more during the calendar year, PacifiCorp will 12
notify Idaho Power. In addition, under compliance with the 13
Sarbanes-Oxley Act, forecasts for projects over $1 million 14
that change by 10 percent or more during the calendar year 15
must be approved by both Bridger Co-Owners. 16
Q. Please describe the Company’s participation 17
in the Bridger capital investment discussions that meet the 18
contractual rights described above. 19
A. Mid-year, the Co-Owners hold a capital 20
budget review where the forecasted capital projects 21
expected to occur over the next three calendar years over 22
$50,000 are discussed in detail. In addition, large capital 23
projects expected over the next decade are reviewed, unit 24
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Idaho Power Company
overhauls, and the scope and need of projects are 1
discussed. Following the meeting, plant personnel 2
consolidates and finalizes the list of all projects, 3
including the scope, need and consequence for each. 4
Following the quarterly Ownership Meeting that 5
occurs in September, the plant personnel present a formal 6
capital and O&M expense budget for the following year as 7
well as a high level 10-year forecast. The intent of the 8
meeting is for the Bridger Co-Owners to ask questions of 9
the plant personnel, most often the subject matter experts, 10
about any details surrounding the forecasted capital 11
investments and O&M expense. 12
Q. How does the Company monitor the budget? 13
A. During each quarterly Ownership Meeting, a 14
standing agenda item is to review the current year capital 15
and O&M expense budget, routinely providing Idaho Power the 16
opportunity to raise any questions necessary about upcoming 17
projects. Additionally, on a monthly basis, forecasts for 18
capital and O&M expense are provided for review by the 19
Company. 20
Q. What is the time period for which Idaho Power 21
is requesting a prudence determination of Bridger 22
investments? 23
A. Order No. 35423 found that investments made at 24
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Idaho Power Company
Bridger through December 31, 2020, had been prudently 1
incurred therefore the Company is requesting a prudence 2
determination on the Bridger investments made during the 3
January 1, 2021, through December 31, 2022, time period. 4
There have been a number of investments required to operate 5
the plant in a safe, efficient, and reliable manner, 6
including investments required to ensure environmental 7
compliance as well as a number of investments for routine 8
asset replacement. 9
Exhibit No. 3 presents Idaho Power’s share of the 10
investments made at Bridger between January 1, 2021, and 11
December 31, 2022, detailing 216 different projects 12
totaling $19.33 million. In addition, for those projects 13
for which Idaho Power’s ownership share is over $100,000, 14
the Company has included a project description and 15
investment purpose classification as to whether the 16
investment was for environmental compliance, safety, and/or 17
reliability. Of the 61 projects for which a detailed 18
project description and investment purpose classification 19
was provided, 31 were for continued reliable plant 20
operations, 17 were required for environmental compliance, 21
one was for safety, and 12 were for a combination of either 22
reliability, environmental compliance, or safety. 23
Q. Were all the projects comprising the $19.33 24
million in investments that occurred between January 1, 25
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Idaho Power Company
2021, and December 31, 2022, necessary for either 1
environmental compliance, the safe and economic operation 2
of the plant, or for reliability purposes? 3
A. Yes. 4
Plant Reliability Investments 5
Q. You indicated there were 31 investments 6
greater than $100,000 that were required for the reliable 7
operation of the plant. What was the largest investment 8
made to maintain reliability? 9
A. The largest investments in both 2021 and 2022 10
required for continued reliable operations of Bridger, as 11
well as 12 others, were associated with the normal wear and 12
tear of existing plant equipment. The two largest projects 13
as well as two other projects, were the result of the 14
accumulation of failures of either pumps, valves or 15
gearboxes during the year, for a total of $1.34 million. 16
These failures and subsequent replacements were unplanned 17
and not budgeted but resulted in capital improvements 18
required to maintain reliability of the plant. 19
In addition, $2.04 million in investments were made 20
(1) for the overhaul of two pulverizers per year, (2) the 21
repair of the primary air ducts that had developed leaks 22
over the years of operation, (3) the replacement of the hot 23
end and cold end seals in both air pre-heaters during an 24
overhaul of Units 2 and 4, (4) the replacement of warped 25
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Idaho Power Company
sector plates on both Units 2 and 4, (5) new boiler side 1
wall tubes required due to increased ash erosion on Units 2 2
and 4, (6) restoration of turning vanes that had been worn 3
through by fly ash on both Units 2 and 4, (7) replacement 4
of high pressure turbine packing on Unit 2, and (8) 5
installation of new mill discharge valves on the units to 6
isolate the supply of fuel to the boiler. 7
Q. How would you categorize the next set of 8
Bridger investments made for continued reliable operations 9
of the plant? 10
A. There were 7 projects totaling approximately 11
$1.38 million associated with the replacement of obsolete 12
equipment that was no longer supported and the repair or 13
replacement parts were costly. This included the upgrade of 14
the electro-hydraulic pumps on Unit 2 and Unit 4, a new 15
continuous vibration monitoring system for the Green River 16
pump station, a digital front end excitation system 17
retrofit, the replacement of both Unit 2 and Unit 4’s DCS, 18
and the replacement of flame scanners on Unit 4. 19
Q. What were the remaining investments required 20
for the reliable operation of Bridger? 21
A. Neural network combustion controls and a soot 22
blowing optimizer were installed on Unit 4 to lower 23
emissions and improve heat rates for a total of 24
approximately $218,000. To assure proper alignment with 25
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Idaho Power Company
both the rotating element and the pump to the turbine, the 1
boiler feed pump was rebuilt, and the casing replaced for 2
$199,000. Approximately $184,000 was associated with the 3
re-build of a failed boiler circulating pump for future re-4
use. Pulverizer journals were replaced as it was more cost-5
effective than repairing, totaling approximately $160,000. 6
Radio communications were upgraded increasing bandwidth in 7
and around the plant for $131,000. On Unit 4, retracts and 8
water injection penetration equipment was installed for 9
$122,000 to help burn the existing coal. The existing 10
feedwater heaters were replaced to drain the system more 11
efficiently and return the water to the condensate system 12
for reuse as opposed to dumping, for a total investment of 13
$245,000. Finally, a new acoustic leak detection was 14
installed in the boiler of Unit 4 for approximately 15
$177,000. 16
Q. Please summarize the investments made at 17
Bridger during the January 1, 2021, through December 31, 18
2022, time period that were necessary for continued 19
reliable operations of the plant. 20
A. In summary, there were 31 projects greater 21
than $100,000 that were required for the reliable operation 22
of the plant in 2021 and 2022 for a total of $6.19 million, 23
or 32 percent of the total investments. 24
Q. You mentioned some of the investments over 25
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Idaho Power Company
$100,000 were made for a combination of either reliability, 1
environmental compliance, or safety purposes. Were there 2
any additional investments for which the purpose included a 3
reliability component? 4
A. Yes. There were eight projects for a 5
combination of reliability and safety purposes and three 6
projects for a combination of reliability and environmental 7
compliance. 8
Plant Reliability and Safety Investments 9
Q. Please describe those projects greater than 10
$100,000 that have been identified as required for 11
reliability and safety purposes. 12
A. The largest investment required for 13
reliability and safety purposes, totaling $308,000, 14
replaced the electromechanical trip system and eliminated 15
the mechanical over speed bolt on the boiler feed pump 16
turbines because the existing system was over 30 years old 17
and maintenance issues had been increasing. Two projects 18
involved the installation parts on Unit 4: new wear plates 19
for the submerged drag chain conveyor and an automatic 20
sprinkler system, for approximately $287,000. The remaining 21
five projects were associated with the replacement of 22
existing investments. 23
Q. What investments were replaced and necessary 24
to ensure reliable and safe operations of Bridger? 25
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Idaho Power Company
A. The feeder breaker relays on Unit 4 were 1
replaced because the existing relays were obsolete. Also, 2
Unit 4 required the replacement of the coal pipes from the 3
pulverizers to the boiler due to high wear from the 4
abrasiveness of the coal. A dozer with the highest 5
operating hours and requiring the most maintenance was 6
rebuilt. A failed epoxy liner and the stator leak monitor 7
system were both replaced on Unit 2. The remaining five 8
projects totaled approximately $971,000. 9
Plant Reliability and Environmental Compliance Investments 10
Q. What three investments were required for the 11
combination of reliability and environmental compliance? 12
A. Both Unit 2 and Unit 4 required the 13
replacement or repair of the burner components due to 14
damage or warped hardware for a total of $406,000 and 15
$648,000, respectively. In addition, new secondary air flow 16
monitors were required on Unit 4 for approximately 17
$175,000. 18
Environmental Compliance Investments 19
Q. What investments were made at Bridger solely 20
for environmental compliance? 21
A. There were 17 projects necessary for 22
environmental compliance. The largest of the investments 23
made at Bridger since 2020 was for environmental compliance 24
and required the replacement of two levels of Selective 25
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Idaho Power Company
Catalytic Reduction (“SCR”) catalyst. The Bridger catalyst 1
management plan requires the replacement of catalysts on a 2
set cycle of every four years or coincident with major 3
outages. The extent of catalyst replacements depends on an 4
evaluation of the condition of the catalyst which will 5
determine how many layers must be replaced to ensure a 6
fully functioning SCR for compliance with environmental 7
regulations. Two layers of the catalyst on Unit 4 were 8
replaced totaling approximately $1.41 million. An 9
additional 12 more projects necessary for environmental 10
compliance were associated with investments in Unit 4, 11
totaling $3.76 million. These included: (1) the extension 12
of the pin block liner to the mid-level of the stack, (2) 13
the replacement of discharge electrode wires in the 14
precipitator, (3) the repair and recoat of the scrubber 15
ductwork, (4) installation of online catalyst cleaning 16
equipment to reduce ash pluggage, (5) installation of a new 17
large particle ash screen to maintain optimal catalyst 18
performance, (6) upgrade of the transformer-rectifiers and 19
current limiting reactors in the precipitator, (7) repair 20
and recoat of the precipitator ductwork, (8) installation 21
of turning vanes and flow straightening devices, (9) 22
replacement of Nuva feeder piping (10) the overhaul of the 23
mini drag-chains that transport ash from the SCR large 24
particle ash hopper to the drag chain hopper, (11) the 25
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Idaho Power Company
purchase and install of Limitorque drivers on the 1
precipitator inlet and outlet dampers, and (12) the 2
replacement of six discharge electrode rappers. 3
Q. What were the remaining four projects 4
necessary for environmental compliance? 5
A. Similar to Unit 4, the repair and recoat of 6
the scrubber and precipitator ductwork on Unit 2 was 7
required as was the replacement of the rapper shaft, 8
bearings, and hammers of the precipitator rapping systems. 9
Finally, a redundant soda liquor supply line was installed. 10
In total, there were 17 projects necessary for 11
environmental compliance, totaling $5.73 million, or 30 12
percent of the total investments. 13
Environmental Compliance and Safety Investments 14
Q. Please describe the investments required for 15
environmental compliance and safety of Bridger. 16
A. There was just one project necessary for both 17
environmental compliance and safety of the plant personnel, 18
totaling $139,000. The coating in the ducts from the 19
scrubbers into the stack was worn so it was replaced. This 20
is a high wear area and if not repaired or replaced will 21
lead to excessive leaking and ultimately environmental 22
violations. In addition, the leaking flue gas could be a 23
hazard to plant employees.24
BARRETTO, DI 47
Idaho Power Company
Safety Investments 1
Q. Were there any investments at Bridger made 2
solely for safety purposes? 3
A. Yes. One investment, for approximately 4
$127,000, was made for safety purposes. The existing 5
outdated station breaker relays were a safety concern due 6
to arc flash hazards and were upgraded. The plant has been 7
replacing the old relays with arc flash compliant relays 8
that will significantly reduce the hazard or arc flash 9
incidents to plant personnel. 10
Q. Please summarize the investments that were 11
made at Bridger over $100,000 that make up the $19.33 12
million for which Idaho Power is requesting a prudence 13
determination. 14
A. Of the 61 projects for which a detailed 15
project description and investment purpose classification 16
was provided, 31 were for the continued reliable plant 17
operations totaling $6.19 million, another $5.73 million 18
was associated with the 17 projects required for 19
environmental compliance, one project at $127,000 was 20
required for safety purposes, and the remaining 12, which 21
were for the combination of either reliability, 22
environmental compliance, or safety, contributed to $2.93 23
million of the total investments made at Bridger between 24
January 1, 2021, through December 31, 2022. 25
BARRETTO, DI 48
Idaho Power Company
V. CONCLUSION 1
Q. Please summarize your testimony. 2
A. The Preferred Portfolio in the 2021 IRP 3
reflects an early exit of coal-fired operations from both 4
Valmy and Bridger as a more favorable economic outcome. The 5
Company has been required to make investments at Valmy and 6
has been actively involved in the capital spend decision 7
making process at the plant. Of the 44 projects for which a 8
detailed project description and investment purpose 9
classification was provided, 26 were for the continued 10
reliable plant operations totaling $4.50 million, another 11
$234,000 was associated with the three projects required 12
for environmental compliance, and the remaining 15, which 13
were for the combination of either reliability, 14
environmental compliance, or safety, contributed to $2.85 15
million of the total investments made at Valmy between 16
January 1, 2019, through December 31, 2022. 17
With respect to Bridger, the Company has been 18
required to make investments and remains actively involved 19
in the capital spend decision making process at the plant. 20
Of the 61 projects for which a detailed project description 21
and investment purpose classification was provided, 31 were 22
for the continued reliable plant operations totaling $6.19 23
million, another $5.73 million was associated with the 17 24
projects required for environmental compliance, one project 25
BARRETTO, DI 49
Idaho Power Company
at $127,000 was required for safety purposes, and the 1
remaining 12, which were for the combination of either 2
reliability, environmental compliance, or safety, 3
contributed to $2.93 million of the total investments made 4
at Bridger between January 1, 2021, through December 31, 5
2022. While Idaho Power is cognizant of the approaching 6
cessation of coal-fired operations at both Valmy and 7
Bridger, the investments made were prudent and required to 8
ensure the plants remain operational in a safe, efficient, 9
and reliable matter. 10
Q. Does this conclude your direct testimony in 11
this case? 12
A. Yes, it does. 13
// 14
//15
BARRETTO, DI 50
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 Senior Manager of 500kV and 5
Joint Projects. 6
2. On behalf of Idaho Power, I present this 7
pre-filed direct testimony and Exhibit Nos. 1 through 3 in 8
this 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 1st day of June 2023, at Boise, Idaho. 16
17 Signed: ___________________ 18
LINDSAY BARRETTO 19 20
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