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The purpose of this chapter is to demonstrate that Pacific Gas and
Electric Company’s (PG&E or the Company) expense and capital forecasts for the management and operation of its fossil electric generation assets are reasonable and should be adopted by the California Public Utilities
Commission (CPUC or Commission).
PG&E’s Fossil Asset Management Program involves managing and operating four generating units at the Humboldt Bay Power Plant (Humboldt
Bay or HBPP) with a combined maximum normal operating capacity of
135 megawatts.
[1]
The Fossil Asset Management Program also includes costs associated with other fossil generation assets that PG&E owns but are no longer operating including the Kern Power Plant, the Hot Oil Pipeline, and the Hercules Pump Station.
PG&E’s primary objective is to safely and reliably operate the fossil generation assets in accordance with all applicable federal and state laws and regulatory requirements in order to provide adequate energy and ancillary services to ensure local area electric system reliability.
PG&E requests that the Commission authorize its capital expenditure forecast of $1.9 million for 2005, $2.5 million for 2006 and $3.4 million for
2007. The 2007 capital expenditure forecast represents an increase of
106 percent over the recorded capital expenditures in 2004. PG&E is also providing specific capital expenditure forecasts for 2008 and 2009 of
[1]
PG&E’s other remaining fossil power plant is the Hunters Point Power Plant
(Hunters Point or HPPP) located in San Francisco on San Francisco Bay.
Hunters Point is scheduled for shutdown in the second quarter of 2006 followed by dismantlement of the facility. Although Hunters Point will not be operational during the period of this GRC, costs associated with the facility are included in the recorded 2004 costs and forecasts for 2005 and 2006 in order to show the effect of the shutdown of the facility.
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$1.7 million and $8.3 million, respectively, to support the generation attrition proposal submitted in Chapter 13 of this exhibit. PG&E also requests that the Commission authorize its 2007 forecast of $13.9 million for operation and maintenance (O&M) expenses. This expense forecast represents a decrease of 35 percent from the recorded expenses in 2004. In addition,
PG&E requests that the Commission authorize its forecast 2007 weighted average fuel oil inventory of $0.8 million.
[2]
These forecast levels of spending are necessary for PG&E to safely and reliably operate and maintain the fossil generating facilities for the benefit of its customers.
PG&E’s expense and capital expenditure forecasts and fuel inventory for the Fossil Asset Management Program are reasonable and justified because the Company:
Operates fossil assets consistent with all applicable federal and state laws and regulations including environmental requirements and requirements of the California Independent System Operator (CAISO) and their reliability must run contracts (p. 5-3);
Uses state-of-the-art maintenance practices (p 5-3);
Maintains strong working relationships with suppliers and vendors to assure a reliable supply of needed materials and services (p. 5-4); and
Conducts upfront outage planning and “root cause” evaluations (p. 5-4).
The expense forecast for PG&E’s fossil assets is consistent with historical spending after recognizing the retirement of Hunters Point Power
Plant. The capital forecasts reflect, in addition to historical spending, capital investments required at Humboldt Bay necessary to replace components reaching the end of their useful lives and to comply with changing regulatory requirements. These forecasts represent the ongoing capital and expenses necessary to continue safe and reliable plant operations.
The remainder of this chapter is organized as follows:
[2] Based on recorded December 2004 end-of-year balances.
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Program Management Process;
Estimating Method;
Activities and Cost by major work category;
Translation of Program Expenses to Federal Energy Regulatory
Commission (FERC) Accounts; and
Cost Tables.
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Due to the geographical location of HBPP, the facility provides for local area electric system reliability and is operated under a reliability must run contract with the CAISO. Operating strategies and state-of-the-art maintenance practices are implemented to achieve high generator availability, especially during winter storm periods. In order to support local electric system reliability, in recent years Humboldt Bay has been operated at higher capacity factors than in earlier years of the plant’s life. Higher capacity factors result in increased potential for failure of aging plant equipment and a greater dependence on condition monitoring and maintenance planning. These state-of-the-art maintenance practices include:
Condition-based maintenance or reliability-centered maintenance such as oil analysis, performance testing, temperature monitoring, and in some cases allowing a component to run to failure to obtain maximum life without impacts on reliability or availability; and
Diagnostic techniques to allow real-time monitoring of equipment to extend equipment life or forecast the need for repairs. These techniques include vibration monitoring and system/equipment performance trending.
Real-time equipment monitoring reduces emergency work, minimizes unnecessary outages and provides information useful to assess the need for future capital investment in the facility.
To plan and allocate resources efficiently, reduce and eliminate repeat problems, and allow for good cost forecasting and planning, PG&E performs outage planning to assure required work is performed during a scheduled period to minimize outage durations and maximize effectiveness of repairs/inspections performed.
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This planning process is aided by the relationships that PG&E has
(PG&E-3) developed with its suppliers and vendors. PG&E actively manages these relationships in order to contain costs and ensure the availability and expedited delivery of needed supplies and services. Due to the age of the facilities and continued obsolescence of installed equipment, PG&E must work with equipment vendors to evaluate their inventories, business direction and product support to determine the potential need for equipment replacement and upgrades. Maintenance of these relationships enables PG&E to find spare parts and to extend the life of its existing equipment. Otherwise, PG&E would need to upgrade equipment and incur higher capital investment.
PG&E has implemented management and work practices to detect and minimize equipment problems and failures. PG&E uses a process known as
“root cause” evaluation to fully understand equipment failures or operational problems. This process involves comprehensive assessment of a component failure or an operational problem (e.g. personnel errors) and requires a selfcritical evaluation of internal processes and procedures. The root cause evaluation process seeks to determine the actual cause of a problem and not only assures a good understanding of the equipment problem or failure, but results in the identification of corrective actions needed to prevent a recurrence of the event.
Other factors that affect management practices and decisions within the
PG&E Fossil Asset Management Programs include:
Humboldt Bay is operated and maintained in accordance with Operations and
Maintenance Standards issued by the Consumer Protection and Safety
Division of the CPUC in accordance with General Order 167;
Humboldt Bay Units 1 and 2 began operation in 1956 and 1958 respectively, and are nearing the end of their operating life. As part of the long term resource plan, PG&E has requested offers for projects to replace the existing generation at Humboldt Bay. Due to electric system reliability requirements, the existing units at Humboldt Bay will need to remain in operation until such time as replacement generation is available. The limited remaining life of these units affects decisions regarding expense and capital activities. Since it is not yet known if or when replacement generation will become available, for the purpose of this GRC, costs
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(PG&E-3) associated with continued operation of the existing facilities are included. If replacement generation were to become available at some time during the period of this GRC, effects on costs included in this GRC can be addressed as part of the rate proceedings associated with the new facilities; and
Shared resources between the fossil assets and the decommissioned nuclear facility (Unit #3) at Humboldt Bay allows PG&E to maintain and operate the fossil and nuclear facilities at a lower total cost than if the facilities were geographically separated and it were infeasible to share resources. While there is a sharing of resources between the fossil and nuclear units at
Humboldt Bay, the recovery of the SAFSTOR O&M and decommissioning costs for the nuclear unit is addressed in a separate rate proceeding (the
Nuclear Decommissioning Cost Triennial Proceeding,A.02-03-020). PG&E has established standard procedures at the Humboldt Bay facility for allocating resources and expenses to ensure clear cost separation between all fossil and nuclear expenditures.
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Capital expenditure forecasts are determined by identifying the base costs necessary to operate the plant and then specifically identifying projects to replace obsolete systems or install new equipment to meet new needs such as environmental or regulatory requirements or to improve unit reliability PG&E developed the 2007 O&M expense forecast using historical cost data where possible
[3]
(e.g., expenses associated with staffing, routine material, and contract services), and by estimating the costs associated with additional planned activities and identified projects.
The planned activities include day-to-day O&M and planned outages or overhauls. The need for and scope of outages or overhauls directly affects premium labor charges, materials costs, and contracted labor support. These costs vary based on the scope of the outage. For example, a boiler inspection outage may take from one to four weeks where a turbine generator overhaul can easily require 6 to 10 weeks of work. The duration of the unit outage determines the amount of scheduled work to be performed. Unless there are
[3] See Section D for a discussion on impacts on historical comparisons.
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(PG&E-3) required regulatory or environmental modifications, the available time is determined by the boiler or turbine generator activities.
The number or extent of projects performed is determined through equipment monitoring, industry experience or equipment failure rates and available outage time. PG&E tracks this information through various work management processes and, if possible, PG&E plans to perform the necessary work during a unit outage or overhaul. PG&E limits outage duration to as short a period as possible. This is to assure the shortest period of unavailability of the units and to meet the annual availability commitments made to the CAISO.
Where regulations or environmental laws mandate certain modifications be installed by a specific date, other projects, which may have been based on operating hours or industry experience, may be postponed to limit the outage scope.
PG&E manages its existing fossil assets through a centralized program management process. PG&E allocates funds appropriately to address not only priority efforts and developing or emerging work, but also routine work and long-term needs. Program management assures consistency in budgeting and priorities across the generating assets. The expense and capital budgeting process requires each facility to develop annual plans to address labor, materials and contracts, using individual charge numbers or “Order Numbers” [4] for each activity, project, or scope of work. These order numbers are then rolled under PG&E defined groupings called major work categories (MWC). The use of MWCs standardizes cost groups, which allows an evaluation of the planned expenditures against historic spending levels, similar projects and similar activities. The MWCs are also grouped under various functions like operations, maintenance, environmental, or projects (both expense and capital).
All work at the fossil generating facilities is primarily grouped under one of four functions: (1) operations; (2) maintenance; (3) environmental; or
(4) projects (both expense and capital). Annual plans vary based on one-time
[4] Order Numbers are internal identification numbers and include sub-identifiers like Specific Orders and Standing Orders to allow PG&E facilities and personnel to budget and subsequently charge time and materials to specific accounts for tracking and trending expenditures.
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(PG&E-3) system or component upgrades resulting from changing state or federal regulations or needed inspections or repairs. Table 5-1 displays the primary functions and associated MWCs that are managed under the Fossil Asset
Management Program. Following Table 5-1 is a discussion of each of the primary functions and associated MWCs.
The discussion outlines the components used in the development of the annual expenditures, as well as actual examples explaining some of the variations from year-to-year of those planned expenditures. The use of direct historical comparisons for going forward costs is difficult across the various
MWCs because of changes in operation of the facilities, allocations of support services and planned maintenance activities.
Historical comparisons are helpful in the planning of expenditures that are associated with specific scopes of work or fixed efforts like boiler inspections or turbine overhauls. However, even though the scope of work is fairly consistent, the expense can change based on the determination to use in-house labor or to contract for outside services.
[5]
Also, there is a potential for performance indicators to flag unit problems, which will drive additional planning, labor and materials from the historic fixed effort and expense. Historical comparisons work well with fixed staffing levels and historic allocations to perform standard annual activities. However, with the changing operating requirements and expected high capacity factors there will be a need to anticipate and manage potentially more extensive work efforts.
[5] The decision to contract is based on the overall planned work scope, availability of inhouse labor, and the unit’s operating condition which may result in the need for specialty machining or materials.
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TABLE 5-1
PACIFIC GAS AND ELECTRIC COMPANY
FOSSIL ASSET MANAGEMENT PROGRAM
MAJOR WORK CATEGORIES
Line
No. MWC
1
2 AW
3 BJ
4 BY
5 CO
6 DM
7
8 AI
9 BI
10 BZ
11 CP
12 HZ
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14 AK
15 CR
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17 BK
18 CJ
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20 01
21 03
22 05
23 12
24 55
25 80
26 81
Operations Function
Operate Generation Facilities
Operate Computer & Network System
Operate Fossil Gen
Operate Other Generation Facilities
Procure Fuel, Water & Steam
Maintenance Function
Maintain Generation Facility Structures
Maintain Buildings
Maintain Fossil Gen
Maintain Other Generation Facilities
Manage Safety Program
Environmental Function
Manage Environmental Operations
Manage Waste Disposal and Transport
Project Expense
Maintain Other Equip
Fossil Generation Projects
Project Capital
IT - Desktop Computers
Office Furniture & Equipment
Tools and Equipment
Environmental
Decommissioning and Environmental Remediation
Computer Network & Facility
Power Generation Maintain Reliability and Availability
The operations function includes activities such as the labor to operate the fossil facilities and the required support such as clerical and engineering. This function also includes site management as well as support services, materials and contracts associated with operating a safe and reliable plant. MWC BY (Operate Fossil Gen) is used by both Humboldt
Bay and Hunters Point for planning and performing routine operations of the fossil units. MWC CO (Operate Other Generation Facilities) is used by
Hunters Point for planning and performing operations of its combustion turbine unit and handling of distillate fuel. This does not included cost of the fuel. MWC AW (Operate Generation Facilities) is used by Humboldt Bay to plan and perform operations of common structures. MWC BJ (Operate
Computer & Network Sys) is used by Humboldt Bay to plan and perform
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(PG&E-3) operations of its network and computers, and MWC DM (Procure Fuel,
Water & Steam) is used by Humboldt Bay for operating costs associated with handling of fuel oil. This does not include the cost of fuel.
PG&E’s forecast of these expenses, which are primarily labor costs, are developed based on historic expenditures with variations based on planned activities to account for premium time and additional outside support. The operational expenses for both Hunters Point and Humboldt Bay are forecast to be $9.9 million in 2005, $7.8 million for 2006 and $5.2 million for 2007.
The forecast for 2006 reflects a partial year operation for Hunters Point and the forecast for 2007 reflects that Hunters Point will be retired and in the process of being decommissioned.
Plant operation is a fairly consistent function. Staffing levels and operating criteria were evaluated during the historic period and adjusted as necessary for this function. Planned operation activities include clerical and engineering support, warehousing, site management and plant operation services, permits, training, testing activities required by regulatory and other agencies, technical operating services provided by other internal departments and other miscellaneous activities. Activities that are not included in the forecast of planned activities are maintenance, environmental, and specific outage and non-outage projects. The historic averages and the consistency of the operating functions allow the plants to estimate necessary annual overtime hours. Outside services are estimated based on historical experience and an evaluation of any other outside services required each year to support the operating functions.
The maintenance function is used to address activities such as the labor to maintain the fossil facilities as well as some required support such as engineering services. This function is also used for materials and contracts required to safely and reliably maintain the facilities. MWC BZ, (Maintain
Fossil Gen) is used by both Humboldt Bay and Hunters Point for planning and performing maintenance of the fossil generation facilities. MWC AI
(Maintain Generation Facility Structures) is used by Humboldt Bay for planning and performing technical maintenance and Hunters Point for planning and performing maintenance of its common facility. MWC BI
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(Maint. Buildings) is used by Humboldt Bay for planning and performing maintenance of its common facilities. MWC CP (Maintain Other Generation
Facilities) is used by Hunters Point to plan and perform maintenance of common facilities and for maintenance activities associated with other fossil generation assets. MWC HZ (Manage Safety Program) is used by both
Humboldt Bay and Hunters Point for planning and performing maintenance associated with PG&E’s Power Generation Department actions to prevent arc flash hazards associated with electrical switchgear.
PG&E’s forecasts of these expenses are primarily based on historic performance. The maintenance expenses for Hunters Point, Humboldt Bay, and other fossil generation assets are forecast to be $8.3 million in 2005,
$6.5 million in 2006 and $3.6 million for 2007. The decrease in maintenance expenses is primarily associated with the shutdown of Hunters
Point in 2006.
Historic averages and the consistency of the maintenance functions allow the plants’ maintenance supervisors to estimate the annual overtime hours that will be necessary. Outside services are estimated based on historical experience and an evaluation of the other outside services required to support maintenance activities. Planned activities included in the forecast include maintenance and repair of the facilities and infrastructure, training, technical maintenance services provided by other internal departments and other miscellaneous activities.
The environmental function is used to address waste management and required environmental permits. This function is also used for internal labor, associated environmental support services, materials and contracts required for various fees and disposal of waste materials. MWC AK (Manage
Environmental Operations) is used by both Humboldt Bay and Hunters Point and for other fossil generation assets for planning and performing environmental related activities. MWC CR (Manage Waste Disposal and
Transport) is used by both Humboldt Bay and Hunters Point for costs associated with transporting and disposal of hazardous materials.
PG&E’s forecasts of these expenses are primarily based on historic performance. There are variations based on planned activities to account
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(PG&E-3) for outside support, waste handling and disposal costs. The planned activities include environmental monitoring, laboratory analysis of environmental samples, waste disposal and transportation, training, environmental and hazardous material fees, technical hazardous material and environmental services provided by other internal departments or contractors and other miscellaneous activities. The environmental expenses for both Hunters Point and Humboldt Bay are forecast to be
$1.3 million for 2005, $1.1 million for 2006 and $.76 million for 2007. The decline in environmental expenses is primarily associated with the shutdown of Hunters Point in 2006.
Expense projects are developed based on equipment performance and failures, equipment trending, manufacturer recommendations, and unit or equipment operating hours. These projects are normally scheduled during planned maintenance outages that occur every one to two years, or during turbine/generator overhauls that occur every 8 to 10 years. MWC CJ (Fossil
Generation Projects) and MWC BK (Maintain Other Equip), are the primary expense project MWCs used by Hunters Point and Humboldt Bay.
These project expenses consist of labor, material, and contract costs and are developed primarily based on historic costs, vendor bids or estimates. The number and size of projects performed from year-to-year will vary depending on the need and opportunity to perform the project
(e.g., unit outages). Projects to be performed at the Hunters Point and
Humboldt Bay facilities need to also be measured based on the planned remaining operating life of the facility. The expense projects for both
Hunters Point and Humboldt Bay are forecast to be $2.4 million in 2005,
$3.0 million in 2006 and $4.3 million for 2007. The increase in expense projects is primarily due to single projects beyond the scope of routine maintenance, activities that must occur in the 2006-2007 timeframe.
Examples are a more extensive dredging of the fisherman canal, cleaning and inspection of fuel tanks, boiler feed pump overhaul, and seismic upgrades to facilities at Humboldt Bay. The forecasts for 2006, 2007 and
2008 include $206,000, $1.56 million and $403,834 respectively, to fund studies necessary to comply with the Clean Water Act. These studies are
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(PG&E-3) necessary to prepare plans to submit to the responsible regulatory agency by 2008 identifying modifications necessary to the Humboldt Bay cooling water intake system in order to comply with the Clean Water Act.
Capital projects address needed infrastructure upgrades, equipment or component replacements for assets near the end of their useful life, and equipment obsolescence. The fossil assets also require retrofitting of structures to address seismic issues and the installation of new equipment to address environmental issues and regulations.
There are six MWCs used to track different types of capital improvements or replacements at the fossil facilities. They are MWCs 01
(IT
—Desktop Computers), 03 (Office Furniture and Equipment), 05 (Tools and Equipment), 12 (Environmental), 80 (Computer Network & Facility), and
81 (Power Generation Maintain Reliability and Availability). Funding for
MWCs 01, 03, 05 and 80 are based on historic needs, anticipated component or tool replacement, and required system improvements.
MWC’s 01, 03 and 80 are forecast at $29,000 in 2005 to address plant furniture and computer network equipment needs, $25,000 is planned for
2006 and $26,000 is foreca st for these MWC’s in 2007. The forecasts for
2008 and 2009 are $63,000 and $65,000, respectively. The 2005 forecast for MWC 05 is $54,000 with forecasts for 2006 through 2009 of approximately $54,000 per year for tools and equipment.
MWC 12 is for projects that upgrade existing equipment or install new systems or components that are mandated by State or Federal regulations.
The MWC 12 forecast for 2005 is $234,000. No projects are forecast for
2006 and 2007. The forecasts for 2008 and 2009 are $221,000 and $3.4 million, respectively. Through 2009, MWC 12 includes a major environmental project for Humboldt Bay that is necessary to comply with recent environmental requirements. The Clean Water Act requires studies of the cooling water intake system to be performed and recommendations proposed by 2008 for modifications necessary to comply with the Clean
Water Act (see discussion of MWC CJ above)
MWC 81 type projects assure unit reliability and availability. They are normally projects that address major component replacements that result
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(PG&E-3) from equipment coming to the end of its useful life or obsolescence. These projects also require cost-estimating, specifications development, outage scheduling, and potentially long lead-time fabrication of components or equipment (e.g., a feedwater heater could take six months to fabricate and deliver). PG&E is forecasting $1.6 million for 2005, $2.4 million for 2006 and $3.3 million for 2007 for MWC 81. The MWC 81 forecasts for 2008 and
2009 are $1.4 million and $4.8 million, respectively. The forecasts for 2007 and 2009 include boiler modifications of the Humboldt Bay units to implement impending air emission reduction requirements for these units.
In addition to the capital projects discussed above, PG&E estimates that it will perform work to perform decommissioning activities at its fossil generation facilities during the rate case period. This work is included in
MWC 55
– Decommissioning and Environmental Remediation. This work will be performed at Hunters Point, Humboldt Bay and Kern Power Plants.
PG&E is forecasting $2 million in 2005, $17.3 million in 2006, $28.3 million in 2007, $20.3 million in 2008 and $4.8 million in 2009 for MWC 55. The breakdown for each facility is shown in the workpapers for Chapter 9,
Generation Depreciation Reserve and Expense.
PG&E’s program managers manage their program costs using the SAP view of cost information, not the FERC account view. Thus, for presentation in this GRC, certain SAP dollars must be translated to FERC dollars. This is not an issue for capital costs where the SAP and FERC view are identical.
[6]
For
O&M expenses, however, the SAP dollars include certain labor-driven adders such as employee benefits and payroll taxes that are charged to separate FERC accounts. These labor-driven adders must be removed from the SAP dollars for
O&M expenses to present them by FERC account.
Tables 5-4 through 5-17 show how the SAP expense dollars in the Fossil
Asset Management Program translate to the appropriate FERC accounts. The expenses are presented by subprogram, MWC and FERC account in sequence
[6] Capital costs are typically shown in rate case filings with overheads (i.e., SAP
“adders”) included, such as capitalized employee benefits and payroll taxes.
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(PG&E-3) by SAP nominal dollars, nominal dollars by FERC account and 2004 dollars by
FERC account.
The calculations used to deflate the nominal dollars to recorded 2004 dollars (which requires segregating them into their labor and non-labor components) are shown in the workpapers supporting this chapter.
The capital and expense requests for the Fossil Asset Management
Program are summarized in the following tables:
Table 5-2 lists the capital MWCs, showing 2004 recorded expenditures and
2005 through 2009 forecast expenditures by MWC;
Table 5-3 lists the expense MWCs, showing 2004 recorded expenses and 2005 through 2009 forecast expenses in SAP dollars, stated in current year dollars;
Tables 5-4 through 5-17 display the 2004 actual expenditures and 2005 through
2009 expenses by subprogram, MWC, and FERC account. Each subprogram set of tables is in sequence by nominal dollars, nominal dollars by FERC account and 2004 dollars by FERC account; and
Table 5-18 lists fuel cost for 2004 recorded and 2005 through 2007 forecast.
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