20101116Crane redacted Reb, exhibits.pdf

Ri:CÇ'. .~....;i
Lßin NO" i G AM to: i 1
i\,QlgiPUTkllk.:
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF ROCKY )
MOUNTAIN POWER FOR )
APPROVAL OF CHANGES TO ITS )
ELECTRIC SERVICE SCHEDULES )
AND A PRICE INCREASE OF $27.7 )
MILLION, OR APPROXIMATELY )13.7 PERCENT )
CASE NO. PAC-E-I0-07
Rebuttal Testimony of Cindy A. Crane
REDACTED
ROCKY MOUNTAIN POWER
CASE NO. PAC-E-I0-07
November 2010
1 Q.Please state your name.
2 A.My name is Cindy A. Crane.
3 Q.Are you the same Cindy A. Crane who has testified previously in this cae?
4 A.Yes, I am.
5 Q.What is the purpose of your rebuttal testimony?
6 A.The purose of my testimony is to:
7 . Rebut the testimony of Idao Public Utiities Commssion Staf ("IPUC")
8 witness Mr. Joe Leckie regarding IPUC's proposed disallowance of the
9 Company's Fuel Stock; and,
10 . Rebut the testimony of PacifCorp Idaho Industral Consumers ("PUC")
11 witness Mr. Randa J. Falenberg regarding fuel qualty problems at the
12 Jim Bridger plant.
13 Fuel Stock Adjustment
14 Q.Please summarize the adjustment that IPUC witness Mr. Leckie recommends
15 in regards to fuel stock.
16 A.Mr. Leckie proposes to limit the coal inventory level for each plant site to no
17 more than the actual tons as of December 2009. Mr. Leckie questions the
18 necessity of increasing the tonnage size of the stockpiles from 2009 actual to 2010
19 pro forma and believes that customers should receive the benefit of the
20 Company's abilty to operate six coal sites at their reduced tonnage levels but
21 should not bear the cost of the increase tonnage at the other coal sites without just
22 and reasonable cause.
REDACT
Crane, Di-Reb - 1
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Do you agree with Mr. Leckie's adjustment?
No, the Company believes that Mr. Leckie did not consider all the facts before
makng his recommendations.
Please explain.
First, by limiting inventory levels to no more than the actual tons in inventory as
of December 2009, Mr. Leckie grossly overstates the increase in coal inventory
for the Uta plants. Mr. Leckie's analysis implies that coal inventory levels in
Utah increased by 300,691 tons durng the test period whereas the pro form test
period reflects only an increase of only 66,606 tons, see Exhbit No. 64. Second,
Mr. Leckie's analysis fails to recognize that the actual inventory levels as of
December 2009 for the Bridger, Naughton and Hayden plants were below
Company tagets. The test period reflects inventory levels at these levels
conformg to established targets by year-end.
Pleas explain Mr. Leckie's adjustment for the Utah inventories?
Mr. Leckie incorrectly assumes that all the Utah stockpiles are independent of
each other. For instance, Mr. Leckie assumes that stockpile reductions at the
Huntigton plant, (228,206) tons, and Carbon plant, (5,879) tons are unrelated to
the increase in the Rock Garden of 246,400 tons.
Are the Huntington and Rock Garden stokpiles interrelated?
Yes. Al of the Deer Creek mie's production is delivered to the Huntigton plant
via an overland conveyor. A mimal amount of coal is maintaed in silo at the
Deer Creek mine. Depending upon mie production levels and quality, Deer
Crek coal could be trsferred from the Huntington plant to Carbon, Hunter,
REDACT
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Rock Garden or Prep Plant. The Rock Garden pile is located approximately 3
mies from the Huntington plant. The Rock Garden pile provides storage and
blending capabilty for the Utah coal fleet. Deer Creek coal production comprises
almost 95 percent of the Rock Garden inventory.
How much Deer Creek coal was transferred from the Huntington plant to
the Rock Garden?
The Company transported almost 228,000 tons of high British therm unit
content, low ash Deer Creek coal from the Huntington plant to the Rock Garden
durng the first half of 2010. Essentially,the increase in the Rock Garden
inventory is offset by corresponding decreases in stockpiles at the Carbon and
Huntington plants.
Does the test period reflect increases at other Utah sites?
Yes. As shown in Exhibit No. 64 the stockpiles at Hunter and the adjacent Prep
Plant increase by 2,755 tons and 51,035 tons respectively, or 53,790 tons in tota.
Please explain the increase at the Prep Plant and Hunter plant.
The majority of the coal is supplied by Arch's Sufco mie under a long-term coal
supply agreement. The Arch contract provides for a price reset of the Sufco
contract in 2011. Though the pares ar still in negotiations, the Company
projects the 2011 contract price wil increase by
_, if not more, over the 2010 price. The Company has prudently
minimied futu costs by purchasing and stockpilg the lower priced coal in
2010 and reducing the amount of Sufco coal purhase in 2011.
REDACT
Crane, Di-Reb - 3
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Is this consistent with the Company's inventory policy?
Yes. The Company's inventory policy contemplates increasing inventory levels if
there are opportnities to procure coal at below-market prices. This prudent
management benefits customers, the slight increase in coal inventory carring
costs is more the offset by the lower purchase price of the coal.
Are any of Mr. Lekie's proposed adjustments to the Utah stockpiles
appropriate?
No. Clearly, the transfer of Deer Creek coal from Huntington to the Rock Garden
is causative of their large but opposite inventory swings. Increasing stockpiles at
both Hunter and the Prep Plant wil benefit customers: the savings in fuel costs
wil more than offset the increased caring charges. As shown in Exhibit No. 64,
Mr. Leckie's proposed adjustment of $15,970,759 (system) decreases to
$7,782,604 (system) after the erroneous Utah stockpile adjustments have been
removed.
Are there other additional problems with Mr. Leckies' analysis?
Yes, the Company disagrees with Mr. Leckie's contention that the stockpile
increases at Bridger, Naughton and Hayden are not just and reasonable. The
stockpile levels at these plants were considerably below Company inventory
targets as of December 2009. The test period forecast reflects these stockpiles
reaching Company targets by the end of the test period. In fact, as of September
2010, actual inventory levels at the Bridger and Naughton plants were slightly
above year-end test period balances.
REDACTED
Crane, Di-Reb - 4
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Please describe the available coal supplies in Southwest Wyoming.
There are only thee mines curently in operation in Southwest Wyoming: Black
Butte, Kemmerer and Bridger CoaL. Total. annual production from these th
mines is estimated at 14.5 millon tons, the Jim Bridger and Naughton plants
consume almost 80 percent of this production. The lack of a rail unloading
facility at the Naughton plant and the absence of other proximate supply
alternatives would severely hamper the abilty of Naughton and Bridger plants to
respond to production shortfalls.
Please explain the Company's inventory target for the Naughton plant.
The Company has established a 45 - 55 day inventory taget for the Naughton
plant. A cessation in production at the Kemmerer Mine would require the
Company to divert coal supplies from either the Bridger Mine or Black Butte
Mine to the Naughton plant. Such deliveries would be contingent upon the
Company's abilty to secure sufficient trcking capacity to support the 125 mile
hauL. Based on prior experience, .the Company believes it could tae upwards of
two months to mobilze a trcking operation that could sustan the plant.
Doe the Naughton plant's test period ending balance conform to the
Company's inventory taets?
Yes, the test year ending inventory balance of 350,267 tons is equivalent to
approximately 47 days of inventory which is slightly less than the midpoint of the
established inventory taget. Furer, as of September 2010, there was 359,046
tons of coal stockpiled at the Naughton plant.
REDACTD
Crane, Di-Reb - 5
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Please explain the Company's inventory target for the Bridger plant.
The Company has established a 50 - 55 day inventory target for the Jim Bridger
plant. The supply risk associated with underground mining is drmatically
different than a typical surace mine. Quality and mining conditions can var
creating both supply and blending challenges.
What steps has the Company purued to increase the supply security at the
Bridger Plant?
In early 2009, the Bridger plant received a permt from the Wyoming Deparment
of Air Quality allowing the increase of its long-term (dead) storage from 500,000
tons to 1 millon tons. When combined with the short-term storage, Jim Bridger
plant's inventory capacity wil eventually expand to 1.3 millon tons. Per permt,
this increase wil be accomplished over a thee-year period: 2009 though 2011.
The permt also limited the plant to increasing its long-term pile by no more than
200,000tons per year.
How much coal is now stored in the Bridger Plant's long-term storage pile?
At the end of September 2010, PacifCorp's share of the long-term pile was
approxitely 567,000 tons. PacifiCorp' s share of the Bridger plant stockpile,
long-term and short-term, as of September 2010 was slightly above 800,000 tons
or 51 days.
Do customers benefit from the increa in the long-term storage pile from
500,00 tons to 1 millon tons?
Yes. The Bridger Plant is the Company's largest generating sour. Alost 50
percent of the plants' requirements are now supplied by the Bridger underground
REDACTED
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mine. The increased inventory level minimizes the supply risk associated with
underground mining.
Has the Company engaged a third party consultant to review Bridger and
Naughton stockpile levels?
Yes, in early 2010, the Company retaned the engineering firm of Pincock Allen
& Holt (PAH) to analyze inventory levels for the Company's Wyomig coal fired
power plants. The Company's inventory targets are consistent with PAH's
recommendations.
Please explain the increase at the Hayden Plant?
The majority of the coal is supplied by Peabody's Twentymile Mine, an
underground mining operation. Until the rai unloading facility commences
operation in 2012, the Company has tageted approximately 60 day inventory
target.
Are there any plants whose inventory levels were above Company targets as
of December 2009?
Yes, inventory levels at the Cholla, Craig and Dave Johnston plants were above
target. The test period reflects the inventory levels at these plants reduced to
Company taget by the end of the test period.
How doe Mr. Leckie treat thes plants in hi analysis?
Mr. Lekie readily accepts the Company's projected inventory reductions at these
plants while ignorig those plants whose inventory levels were increased to algn
with prudent inventory taget levels.
~)REDACTED
Crane, Di-Reb - 7
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Does the Company expect to reduce inventory levels?
There are no plans to reduce plant inventory levels below test period ending
balances. The Company wil continue to seek opportnities to efficiently manage
fuel cost and quality though effective management of its inventory. Furher, the
Company may need to revise its inventory targets in Utah to even higher levels as
longwall mining operations continue to deplete and the Company faces uncertain
labor negotiations with the Deer Creek represented workforce.
Can you please identify the primary driver of the Company's increse in test
period fuel stock?
Yes. Of the $24.6 mion system increase in fuel stock, $24.9 millon is drven
by price increases in the cost per ton coal, with $0.3 milion reduction due to
volume related costs as reflected in Exhbit No. 64.
Did Mr. Leckie review the average price per ton per stockpile?
Yes, Mr. Leckie found the average cost per ton to be reasonable for valuing the
total value of stockpile.
Please summarize the Company's position regarding the IPUC Staff's
proposed fuel stock diallowance.
The Company believes the Commssion should reject the IPUC Staf s proposed
$15,970,759 disallowance. Mr. Leckie adjusted inventory levels in Utah without
considering the interrelationship between stockpiles and the economic benefits of
the higher stockpile levels in Uta. Furer, Mr. Leckie's analysis ignores the
supply risks associated with maitag adequate inventory levels, parcularly in
Wyomig.
REDACTED
Crane, Di-Reb - 8
Rocky Mounta Power
1 Jim Bridger Fuel Deration
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Please explain PUC's, proposal related to the fuel at the Bridger Plant.
PUC argues that the quality of fuel at the Bridger Plant has resulted in an
unnecessary high number of derations at the plant. PUC argues that additional
costs resulting from fuel quality problems at the Bridger Plant be disalowed,
resulting in $800,037 (system) decrease in net power costs. PUC also proposes to
remove $1,660,000 (system) related to labor and benefits costs at Bridger Coal
from the test period expenses.
Do you agree that the fuel quality at the Bridger plant resulted in additional
derations relative to other coal plants?
Yes. All coal plants are affected by changes in coal qualty and their abilty to
blend coals. In coal mining, quality can var dramaticaly from seam to seam or
within a seam. Both Bridger Coal Company and the Jim Bridger Plant have
established coal quality targets for heat value, ash, sulfu, sodium, etc. Though
vigorous blending, both the Bridger mine and the Bridger plant minie qualty
varations that undermne optimal plant performance.
Are there times when Bridger Coal deliveries have not met established
taets?
Yes. Although the Bridger mine does attempt to deliver a consistent product, at
times it is lited by the size and qualty of the mine stockpiles and physical
logistics. Bridger mine's surace operation historically delivered a consistent coal
blend though mining of coal in multiple exposed seams. The development of the
underground mine and the scalng back of the surace operation has resulted in
REDACTED
Crane, Di-Reb - 9
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increased blending requirements, greater unpredictabilty in coal deliveries and
the potential for extended periods of high ash coal production.
For instance, if the longwall system is in an area in which the coal seam thickness
is less than the minimum cutting height of the longwall shearer, coal quality wil
be negatively impacted. Similarly, if the coal seam is diluted with in-seam
par~gs, coal quality wil be negatively impacted.
How has Bridger Coal quality changed with underground miing?
Bridger Coal Company's ash content is curently the critical quality characteristic.
As reflected in the char below, Bridger Coal Company and the Bridger Plant
have established 13 percent as the maximum ash content for optiml plant
performance. Pror to underground mining, the mie consistently delivered the
Jim Bridger plant coal with a mamum of 13 percent ash. With the advent of
underground mining, however, the calculated ash content has at times exceeded
13 percent ash.
REDACTD
Crane, Di-Reb - 10
Rocky Mounta Power
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Bridger Coal Company: Underground Mine Ash Contentvs Target
25.00 .f........ ...............................................................................................................................................................
23.00 T...... ...............................................................................................................................................................
21.00 i'...... . ................................. ...,........................................................................................................................
19.00 1".... .... ................ .............. ...............,..........................................................................................................
I! 17.00 .f..... ..... ............. .... ......... .. ..........................................................................................................................¡ ¡ l
! 15.00 r........... .. ...... ......... .... .... .... ..c.......................................................... ... ............................ .... ..............
i 13.00 +
I 11.00 1"...............................................................
I::: '//;7;/;;7/~?;7;;~~;~;~~-%Ash -PlantTarget fè 13% Ash
t.....................................................__..____..............u................................................__...............................__..................................:
Does the Company routinely blend for ash content at its other locations?
All of the coal produced in Utah is curently from underground mining. All of
these mines, at times, produce coals that do not meet contract specifcations. Coal
stockpiling and blendig facilities at the Hunter and Huntington plants enable the
Company to mix these coals as necessar to provide the power plants with a
consistent coal quality. These facilties alow the Company to effciently and
economically segregate, stockpile, and reclai underground coal based on a
parcular coal quality. Without a simlar facilty at the Bridger Plant, both the
Bridger mie and the Bridger plant are potentialy lited at times in their abilty
to blend Bridger underground coal durg periods of high ash and low heat
content.
REDACTED
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Is Bridger Coal evaluating options to improve its blending capabilties?
Yes. The Bridger mine curently has stacking tubes adjacent to the underground
portal that parially alleviate the quality fluctuations. The mine modified the
stockpile footprint of one of its trck dump stations to fuer segregate coal
quality produced by the underground mine. The mine is evaluating enlarging the
footprint of this truck dump station to create an even larger inventory surace area
to accommodate the expected underground coal quality variabilty.
Do you agree with PUC that costs associated with the additional derations
should be removed from NPC?
No. It is inappropriate to remove costs associated with "low-quality" coal from
the underground mie, but accept the lower coal costs that result from the
favorable economics associated with underground minig. In addition, PUC
incorrctly assumes that the total costs at the Bridger plant would not change from
what the Company has included in its fiing even though the generation at the
plant has increased due to removal of the outages due to "low-quality" coaL.
Are there coal quality advantages with the Bridger underground?
Yes, the lower sodium content allowed the Bridger plant to mize potential
slagging issues from March 2007 though Februar 2009 when the Black Butte
mine delivere high sodium coal. Due to limited production, Black Butte coal
deliveries average in excess of 4.5 percent sodium. The sodium content taget is
less than 3 percent. Without Bridger's lower sodium coal, the Bridger plant
would have sustained deratigs due to boiler slagging.
REDACT
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What impact would increasing the ratio of surace coal to underground coal
have on Bridger Coal deliveries?
Increasing surace production at the expense of the underground production
would likely result in lower ash coal content but higher fuel costs.
Why would Bridger plant fuel costs increae?
Increasing the ratio of surface production would likely reuire additional coal
production as the average heat content of the underground operation is tyically
200 to 300 British thermal units per pound higher than the surface operation.
Additionally, the estimated incremental cost of the surace operation is greater
than the estimated decremental cost of the underground operation.
Please explai the nature ofthe $1,660,000 (system) PUC proposes removing
from test period net power costs as they relate to Bridger Coal?
Almost $1,616,000, or 97 percent, of this disallowance is associated with
management and union incentives at Bridger Coal Company. Each union
employee must meet specific safety goals to be eligible for the incentive, safety
incentives are $698,000 of PUC's adjustment. The remainig amount, $918,000,
is paid to management employees based on each individual's performce.
Management incentives are an importt par of the compensation strctue.
Offering competitive tota compensation, includig wages and benefits, is critical
to Bridger Coal's efforts to attact and retan employees. Bridger mine
maagement employees are eligible for the same annual incentive program as
Rocky Mounta Power employees. Mr. Wilson discusses the Company's
incentive program in his rebutt testiony.
REDACTED
Crane, Di-Reb - 13
Rocky Mountan Power
The remainder of this adjustment is primaly associated with meal expenses. The
majority of the meal expenses are incured during mine safety trainng events for
surace and underground workforce as well as meal expenses associated with
business travel.
. Do you agree with PUC that these labor and benefit costs should be removed
from NPC?
No. PUC's proposed adjustment is arbitrar and is unrelated to coal qualty issues
at the Bridger plant. PUC's disallowance of costs related to mie safety is
completely incompatible with the Company's mission to provide a safe workig
environment. The Company has spent considerable time identifying quality
parameters that result in optimized plant performance for its therml fleet.
Bridger mine and Bridger plant personnel focus on coal deliveries and coal
quality. Since the majority of the coal blending occurs at the Bridger mie,
Bridger mie deliveries are often adjusted daly. Both the increase in Bridger
plant's long-term storage capacity and the Bridger mine's ongoing evaluation of
increasing surace storage capacity are indicative of the Company's focus on
pursuing economic options that maximize performnce.
Doe this conclude your rebutt testimony?
Yes
REDACT
Crane, Di-Reb - 14
Rocky Mounta Power
Case No. PAC-E-I0-07
Exhibit No. 64
Witness: Cindy A. Crane
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Rebuttl Testimony of Cindy A. Crane
Fuel Stock Balances
November 2010
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