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Published by: vibhore1980 on Feb 05, 2011
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  Docket No. UM-1355Exhibit PPL/102Witness: David J. Godfrey           
 PACIFICORP___________________________________________________________  Supplemental Testimony of David J. Godfrey             July 2009
PPL/102Godfrey/1Supplemental Testimony of David J. Godfrey
Q. Please state your name, business address, and present position with
PacifiCorp dba Pacific Power (the “Company”).
2A. My name is David J. Godfrey, my business address is 1407 West North Temple,3Suite 320, Salt Lake City, Utah, and my position is Director, Asset Management4and Compliance for PacifiCorp Energy.5
Q. Have you previously filed testimony in this case?
6A. Yes.  I filed direct and rebuttal testimony in this case.7
Q. What is the purpose of your supplemental testimony?
8A. I discuss two issues:  (1) the non-comparable and non-verifiable nature of the9NERC data Staff proposes to use in its benchmarking proposal for forced outage10rates; and (2) technical problems with Staff’s proposed benchmarking proposal11for forced outage rates, including the fact that Staff set the 90 percent benchmark 12level based upon a “visual interpretation”  instead of statistical analysis and that13Staff proposes a mismatched comparison of one year of plant data to a four-year14benchmark, instead of comparing four years of plant data to a four-year15benchmark.  I also present an analysis of Staff’s benchmarking proposal and16PacifiCorp’s alternate proposal for excluding extreme events from the forced17outage rate.18
Excluding Extreme Events from Forced Outage Rates
Q. Please explain your general concerns about the use of NERC data in Staff’s
benchmarking proposal.
21A. NERC generally supplies information on a summary level, meaning average unit-22year statistics. NERC can provide a frequency distribution of performance indices23
PPL/102Godfrey/2Supplemental Testimony of David J. Godfreybroken out by fuel type and size; however, there is no guarantee that the units in1the frequency distribution remain constant year to year, nor is there any unit-2specific data readily available for the calculated indices.3
Q. Why would it matter whether the units in the NERC data set have different
characteristics from the Company’s units?
5A. Certain characteristics are correlated with higher or lower forced outage rates.  A6significant characteristic not included in the NERC data is the age of the unit.  As7I mentioned in my rebuttal testimony, PacifiCorp has an aging fleet.  Older units8are more likely to have more frequent forced outages.  In addition, certain9operational characteristics and design features may result in higher forced outage10rates.  For example, a unit with a scrubber is more likely to have more forced11outages than a unit that does not since it has an additional piece of equipment that12can break down and cause the unit to shut down.  Operational characteristics, such13as the maintenance of high capacity factors, can also impact the frequency of 14outages.  The NERC data used by Staff does not differentiate between new and15old units, units with or without scrubbers, and units run at relatively high or16relatively low capacity factors.  Because these factors could all materially impact17forced outage rates, it is unreasonable to rely on the NERC data used by Staff as a18basis for forecasting unit-specific forced outage rates.19
At the Commission workshop on May 28, 2009, Staff claimed that the non-
comparability of NERC data was a “very, very small noise factor” in the
analysis.  (Commission Workshop Tr. 66.)  Do you agree?
 22A. No.  The only stated basis for this position was Staff’s “visual interpretation” of 23

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