(PG&E-3) 1 2 3 4 5 6 PACIFIC GAS AND ELECTRIC COMPANY CHAPTER 3 HYDRO OPERATIONS PROGRAM COSTS A. Introduction 1. Scope and Purpose The purpose of this chapter is to demonstrate that Pacific Gas and 7 Electric Company’s (PG&E or the Company) expense and capital 8 expenditure forecasts for its Hydro Operations Program are reasonable and 9 should be adopted by the California Public Utilities Commission (CPUC or 10 11 Commission). PG&E’s hydro system consists of 110 generating units at 12 68 powerhouses. These generating units have a combined maximum 13 normal operating capacity of 3,896 megawatts (MW) and produce an 14 average of 11,672 gigawatt-hours (GWh) per year. 15 Commission adoption of PG&E’s expense and capital forecasts for 16 operating and maintaining the hydro system is necessary to ensure safe, 17 reliable and low-cost generation from these assets in 2007 and beyond. 18 19 2. Summary of Request PG&E requests that the Commission adopt its 2007 forecast of capital 20 expenditures of $103.6 million to maintain a reliable, low-cost hydro system 21 that produces clean, carbon free, energy to meet California’s needs, while 22 meeting all of the federal, state and local regulatory requirements. PG&E 23 further requests that the Commission adopt its 2007 forecast of 24 $143.9 million of hydro operations and maintenance (O&M) expense. 25 PG&E is also providing specific forecasts for 2008 and 2009 to support 26 the generation attrition proposal in Chapter 13 of this exhibit. PG&E 27 requests that the Commission reflect in the attrition adjustments for 2008 28 and 2009 its O&M expense forecast of $150.8 million for 2008 and 29 $158.5 million for 2009 and its capital forecast of $110.1 million for 2008 30 and $117.3 million for 2009. 3-1 (PG&E-3) 1 3. Support for Request PG&E’s capital and expense forecasts are reasonable and justified 2 3 because they ensure continued safe, reliable, and environmentally 4 responsible operation of the hydro system. Currently, PG&E: 5 Safely and reliably operates the hydro system in compliance with all 6 state and federal regulations and the Federal Energy Regulatory 7 Commission (FERC) license conditions; 8 Operates and maintains the hydro system to make energy supply available to meet demand, within the constraints of water usage, 9 10 thereby reducing the overall energy procurement costs charged to 11 customers; 12 collaborative relicensing; and 13 14 Promotes environmental protection, resource stewardship and Maintains energy and ancillary service capabilities to provide ancillary 15 service products to help meet PG&E’s long term needs. 16 Hydro Operations’ forecast reflects increased 2007-2009 spending 17 associated with the following major business drivers: 18 facility safety and environmental regulations; and 19 20 New regulatory fees imposed on the hydro assets by State and Federal agencies; and 21 22 License conditions associated with new FERC licenses along with new Investment in generation efficiency improvements that reduce the costs 23 to PG&E’s customers while increasing California’s source of clean, 24 carbon free, energy; and 25 Automation and other improvements to the hydro infrastructure to 26 comply with new, sometimes complex, license requirements at the least 27 cost. 28 4. Organization of the Remainder of This Chapter The remainder of this chapter is organized as follows: 29 30 Program Management Process; 31 Estimating Method; 3-2 (PG&E-3) 1 Activities and Costs by Subprogram/Major Work Category (MWC); 2 Translation of Program Expenses to FERC Accounts; and 3 Cost Tables. 4 5 B. Program Management Process PG&E manages both expense and capital expenditures for its hydro assets 6 through one centralized program. This program consists of six subprograms 7 and uses 16 expense MWCs (regulatory fees are also segregated) and 8 five capital MWCs. This section describes the Hydro Operations Program, 9 including background information on the age and condition of the assets and a 10 description of the support organization. PG&E includes this information to assist 11 the Commission and other participants in the General Rate Case (GRC) 12 proceeding in understanding the expansive nature of the hydro system and the 13 need for a centralized program management approach to ensure that PG&E 14 systematically invests in the highest value-work. 15 1. Overview and History of the Hydroelectric System 16 PG&E’s 68 hydro powerhouses are located on 16 rivers and 17 four tributaries of the Sierra Nevada, Cascade and Coastal mountain 18 ranges, (see work papers; Figure 3-1). 19 These facilities were built between 1898 and 1986. Most of the dams 20 and powerhouses have been in service for well over 50 years, and some of 21 the water collection and transport systems were used for gold mining and 22 consumptive water prior to the development of the hydro system. 23 The hydro system operates under 26 FERC licenses, which govern the 24 operation of 105 generating units at 65 powerhouses, plus five units at 25 three non-FERC jurisdictional powerhouses with a total generating capacity 26 of 3,896 MW. PG&E’s authority to divert and store water for power 27 generation is based on 92 water right licenses or interim permits, and 28 160 Statements of Water Diversion and Use. 29 Each hydro facility was engineered considering the specific river flows 30 and topography of its site. The system collectively includes the following 31 facilities: 99 reservoirs, 76 diversions, 174 dams, 184 miles of canals, 32 44 miles of flumes, 135 miles of tunnels, 19 miles of pipe, 5 miles of natural 3-3 (PG&E-3) 1 waterways, and approximately 140,000 acres of fee-owned land (refer to 2 Chapter 7, Exhibit (PG&E-3) for a discussion of PG&E’s land conservation 3 commitment). It also includes switchyards, switching centers that remotely 4 control generation facilities, administrative buildings, fleet, multiple modes of 5 communication, materials and supplies inventories, office equipment, and 6 other miscellaneous instrumentation and monitoring equipment. 2. Organization and Operational Efficiencies 7 When the older hydro facilities were constructed, they required on-site 8 staff to operate and maintain the generating equipment and water systems. 9 10 Investment in technological advancements automated the hydro system 11 over the past 100 years, so that today only 8 of the 68 hydro powerhouses 12 are manned during normal operations. Seven of these powerhouses serve 13 as hydro switching centers and the eighth is the Helms Pumped Storage 14 Project. These switching centers and Helms are staffed 24 hours a day and 15 have the ability to call for additional hydro personnel as needed. Powerhouse equipment and water system automation over the past 16 17 decades, including the installation of alarms and controls, have maintained 18 system reliability while reducing the requirement for a number of 19 headquarters, service centers and employee houses. This consolidation 20 has resulted in significant downsizing and cost efficiencies. The current field organization of hydro operations is built around 21 22 five watersheds: 23 Shasta, which includes six FERC licenses covering 16 powerhouses with a combined capacity of 810 MW; 24 25 DeSabla, which includes six FERC licenses covering 12 powerhouses 27 with a combined capacity of 756 MW, and three non-jurisdictional powerhouses[1] with a combined capacity of 8 MW for a total of 28 764 MW; 26 29 Drum, which includes four FERC licenses covering 15 powerhouses with a combined capacity of 218 MW; 30 [1] These facilities are outside of FERC’s licensing jurisdiction because they are located on non-navigable waters. 3-4 (PG&E-3) 1 Motherlode, which includes four FERC licenses covering eight powerhouses with a combined capacity of 318 MW; and 2 3 Kings Crane-Helms, which includes 7 FERC licenses covering 4 13 conventional powerhouses and the Helms Pumped Storage Facility, 5 with a combined capacity of 1,787 MW. 6 3. Service Centers and Reporting Headquarters 8 Hydro Operations’ O&M personnel are assigned to twelve service centers and seven reporting headquarters[2] to handle ongoing hydro O&M 9 work. In addition to personnel assigned to the service centers and reporting 7 10 headquarters, the hydro construction field force is mobile and works 11 throughout the system. Hydro Operations’ centralized staff is located in 12 San Francisco. A series of tables included in the work papers, (Figures 3-2 through 13 14 3-11), list where O&M personnel who have primary responsibility for 15 responding to work assignments throughout the hydro system are located. 16 There are two tables for each watershed region. The first table, titled 17 “Personnel Headquarters,” identifies the locations in each watershed where 18 personnel providing O&M services normally report to work prior to traveling 19 to a remote hydro facility. Work requirements and, hence, staffing vary in 20 relation to the design features of each project. For example, projects with 21 long water conveyance systems require additional water maintenance and 22 water operations personnel. The second table, titled, “Job Classifications Reporting to Each 23 24 Headquarters,” lists the number of employees in each O&M job 25 classification at each service center or reporting headquarters. These 26 employees handle the watershed’s base workload, including emergency 27 response. The number of employees in the column marked full-time 28 equivalent (FTE) are as of June 2005. Switching centers generally have [2] Service centers have administrative offices and may include maintenance facilities and an inventory of tools, equipment, vehicles, material and supplies. Each service center has facilities and equipment designed to meet the needs of the assigned powerhouses. A reporting headquarters serves as a regular point of assembly for hydro operations personnel, but may not include any additional facilities. Service centers discussed herein do not include construction service centers. 3-5 (PG&E-3) 1 five to seven operators in one or two classifications.[3] Each of the 2 seven reporting headquarters generally only has one or two operating 3 personnel assigned to them. Service centers can have up to 35 employees 4 in nine classifications. As shown in these tables, there are only a few hydro 5 employees in each classification at each service center. Hydro Operations’ centralized organization provides oversight and 6 7 direction to ensure that critical resources and personnel are shared between 8 watersheds. This includes a mobile construction organization, which 9 handles major maintenance projects throughout the hydro system and a 10 centralized management team that provides the following services and 11 expertise: 12 Business and information systems; 13 Construction and construction management; 14 Engineering, project management and facility safety; 15 Environmental, health and safety; 16 Land management and recreation facilities management; 17 Licensing, compliance and relicensing; 18 Operations; 19 Maintenance; and 20 Water management. 4. Long-Term Plan (LTP) 21 The LTP, along with Hydro Operations’ condition assessment and work 22 23 management programs, provides data that allows PG&E to assess the 24 physical condition of the assets, identify the projects and resources needed 25 to maintain the facilities properly, and optimizes work schedules and 26 expenditures to minimize the long-term cost of production from these 27 generating facilities. This information is included in the workpapers to this 28 testimony. Benefits resulting from these efforts include: [3] Excluding management classifications. 3-6 (PG&E-3) 1 More efficient utilization of Hydro Operations’ maintenance, operation, planning, design, licensing, and construction staffs; 2 3 Early coordination with support departments to obtain needed resources; 4 5 More efficient utilization of financial resources; and 6 Determination of the proper level of investment to restore and sustain hydro assets. 7 5. Value and Use of the Hydroelectric System 8 PG&E’s hydro plants produce low-cost energy, high-value ancillary 9 10 services and peaking capacity to meet customers’ needs. PG&E has 11 demonstrated its ability to optimize these generation facilities through 12 efficient use of water resources and continuing environmental stewardship. 13 This 2007 General Rate Case forecast identifies the actions and costs 14 required to maintain the system’s existing capabilities for the benefit of 15 customers. 16 The California Energy Commission recognizes that 17 18 19 20 21 22 23 24 Hydroelectricity is an important element of California’s energy portfolio, providing between nine and 30 percent of annual state electricity sales over the last twenty years. In addition to this share of electric generation, the hydroelectric system provides peaking reserve capacity, spinning reserve capacity, load following capacity, transmission support, and extremely low production costs. These attributes have made and continue to make hydroelectricity a key element of the state’s generation system.[4] a. 25 Meeting PG&E’s Customer’s Energy Needs PG&E’s hydro system consists of 110 generating units at 26 27 68 powerhouses with a total generating capacity of 3,896 MW, which 28 represents about 28 percent of California’s hydro capacity. PG&E’s hydro system includes reservoirs which enable PG&E to 29 30 store runoff and aquifer flows and then subsequently use the water to 31 generate power when the customers’ need it most. This “shaping” of [4] California Hydropower System: Energy and Environment; Appendix D, 2003 Environmental Performance Report; CALIFORNIA ENERGY COMMISSION, Prepared in Support of the Electricity and Natural Gas Report under the Integrated Energy Policy Report Proceeding (02-IEP-01); October 2003; 100-03-018. 3-7 (PG&E-3) 1 the available generation is performed both seasonally (for example, by 2 storing more water in the spring and releasing water from the reservoirs 3 during high value hot summer days) and day-to-day (for example, 4 generating more during hours of peak system demand—typically 5 weekday afternoons and evenings and less at night and on weekends). 6 In general, the highest value of generation is likely to be when PG&E’s 7 demand is greatest, and hydro generation can contribute significantly 8 toward reducing the amount of power that has to be purchased during 9 these higher-price hours. b. Cost-Effectiveness of Hydroelectricity 10 Hydropower is the most efficient energy resource, with a 90 percent 11 12 conversion rate of transforming hydraulic forces to electricity. Hydro 13 Operations’ operating costs are low and predictable since there are no 14 fuels to purchase. Once the capital costs are recovered, hydro is the 15 most cost-effective energy source in use today. PG&E’s hydro system 16 provides its customers with 3,896 MW of normal maximum operating 17 capacity and 11,672 GWh of energy in an average precipitation year. 18 The continued availability of this hydro power helps meet the system 19 peak load and plays an essential role in controlling energy prices in 20 California. Maintaining these capabilities can further reduce the cost of 21 obtaining energy or ancillary services to meet PG&E's net open position. c. 22 Load Shaping and Peaking Value of Hydroelectricity While the primary requirement for electric procurement is to meet 23 24 customer energy demand, PG&E additionally provides or procures 25 ancillary services required to maintain electric grid stability. The California Independent System Operator (CAISO) requires load 26 27 serving entities to provide or pay for a proportionate share of the 28 ancillary services needed by the CAISO to maintain electric system 29 reliability. PG&E uses hydro to self-provide the following ancillary services:[5] 30 [5] The definitions are taken from the website of the CAISO: http://oasis1.caiso.com/iso/news/FYIMarkets.html. 3-8 (PG&E-3) 1 Regulation “Up” – Generation that is already up and running 2 (synchronized with the power grid) and can be moved via direct 3 electronic commands by the CAISO above the unit’s scheduled 4 output level, to keep system wide energy supply and energy use in 5 balance (Automatic Generation Control (AGC) market); 6 Regulation “Down” – Generation that is already up and running 7 (synchronized with the power grid) and can be moved via direct 8 electronic commands by the CAISO below the unit’s scheduled 9 output level, to keep systemwide energy supply and energy use in balance (AGC market); 10 11 dispatched within 10 minutes; 12 13 Non-Spinning Reserves – Unloaded offline generation that can be dispatched within 10 minutes; and 14 15 Spinning Reserves – Unloaded online generation that can be Replacement Reserves – Generation that can begin contributing to 16 the grid within an hour. 17 PG&E maximizes the availability of these capabilities by operating 18 the majority of the hydro facilities as peaking facilities. This operating 19 strategy helps meet daily changes in system demands and preserves 20 hydro's rapid dispatch and spinning reserve capabilities for use during 21 higher value periods. Hydroelectric generating units typically start up 22 quickly, have high ramp-rates, and can easily, quickly, and economically 23 vary output in response to changing customer loads and system 24 conditions. In addition, hydro generating units can operate at no-load or 25 low-load with much higher efficiency than the alternative fossil-fueled 26 peaking plants. Finally, because a large portion of California's 27 non-fossil-fueled electricity resources consist of non-dispatchable 28 energy sources such as wind, solar, nuclear and regulatory “must-take” 29 generation, the CAISO relies on PG&E’s hydro resources to satisfy a 30 large portion of its operating reserve requirements. 31 The hydro system provides 90 percent of the ancillary service 32 capabilities required by the CAISO for PG&E’s service territory. This 3-9 (PG&E-3) 1 means PG&E is usually able to self-provide the required ancillary 2 service capability and thus eliminate the need to purchase supplemental 3 capabilities from the market. 4 d. Reliability of Hydroelectricity 5 Hydroelectric generation has one of the highest availability and 6 reliability rates of all generation resources. Customer service reliability 7 is enhanced by the high availability, reliability, and operational flexibility 8 of existing hydro resources. Hydro Operations’ forebay and afterbay 9 storage capabilities allow this mode of operation while complying with 10 the FERC license streamflow requirements. High availability assures 11 full utilization of the available water resources and therefore reduces the 12 average cost of generation The reliability of the electric grid depends on fast, flexible generation 13 14 sources to meet peak power demands, maintain level system voltages 15 and quickly restore service after a blackout. Hydroelectricity can be 16 placed on the electric grid faster than any other energy source. 17 Hydropower’s ability to go from zero power to maximum output rapidly 18 and predictably makes it exceptionally good at meeting changing loads 19 and providing ancillary electric service that maintain the balance 20 between electric supply and demand. Because hydropower is 21 generated within seconds of when water begins rushing through its 22 turbines, hydropower is particularly adept at providing incremental 23 bursts of power. This is of great value to electric power grid operators, 24 which is why they often rely on hydropower‘s speed and flexibility to 25 meet fluctuations in electric power demand and to restore service after a 26 blackout. 27 28 e. Clean, Carbon Free, Source of Power PG&E’s customers benefit from this indigenous, carbon free, 29 resource because it produces no air pollution and hydro power directly 30 offsets the use of non-renewable fossil fuels. In addition, hydro power 31 is a non-consumptive use of water resources that is well integrated into 32 water supply, irrigation, flood control, and other multi-purpose projects. 33 34 On September 12, 2002, Governor Gray Davis signed a bill (SB 1078) requiring California to generate 20 percent of its electricity 3-10 (PG&E-3) 1 from renewable[6] energy no later than 2017. The new law requires 2 sellers of electricity at retail to increase their use of renewable energy by 3 1 percent per year. Since California already generates about 4 10 percent of its electricity consumption by renewables, the new law will 5 6 nearly double the state's existing base of wind, geothermal, biomass, small hydro,[7] and solar energy resources. While all conventional 7 hydroelectric powerhouses are refueled through annual precipitation, 8 only about 295 MW of PG&E’s hydroelectric capacity meet the State’s 9 “small hydro” classification and are thus included in the RPS baseline. f. 10 Natural Resources Stewardship PG&E demonstrated it’s commitment to environmental stewardship 11 12 by reaching an agreement in 2003 with the California Public Utilities 13 Commission to establish the Pacific Forest and Watershed Lands 14 Stewardship Council, a California nonprofit foundation, to permanently 15 conserve beneficial uses of its hydro watershed lands. The Council will 16 provide oversight of the development and implementation of a plan that 17 delineates long-term management objectives for PG&E’s land holdings 18 of approximately 140,000 acres of hydro watershed lands. These lands 19 will be conserved for a broad range of public benefits, including the 20 protection of the natural habitat for fish, wildlife, and plants, the 21 preservation of open space, outdoor recreation by the general public, [6] [7] Renewable — A power source other than a conventional power source within the meaning of Section 2805 of the Public Utilities Code. Section 2805 states: “‘Conventional power source’ means power derived from nuclear energy or the operation of a hydropower facility greater than 30 megawatts or the combustion of fossil fuels, unless cogeneration technology, as defined in Section 25134 of the Public Resources Code, is employed in the production of such power.” Small hydro — A facility employing one or more hydroelectric turbine generators, the sum capacity of which does not exceed 30 megawatts. Pursuant to PUC section 399.12, procurement from a small hydro facility as of January 1, 2003 is eligible only for purposes of establishing the baseline of an electrical corporation. A new small hydro facility is not eligible for the RPS if it will require a new or increased appropriation or diversion of water under Part 2 (commencing with Section 1200) of Division 2 of the Water Code. Pursuant to PUC section 383.5 (d) (2) (C) (iv) as amended by Public Resources Code section 25743(b)(3)(D), a new small hydro facility must not require a new or increased appropriation of water under Part 2 (commencing with Section 1200) of Division 2 of the Water Code to be eligible for supplemental energy payments. 3-11 (PG&E-3) 1 sustainable forestry, agricultural uses, and land to be preserved for 2 historic and cultural values. See Chapter 7 of this exhibit for a more 3 detailed discussion of the Pacific Forest and Watershed Lands 4 Stewardship Council. 5 Hydroelectric projects provide a wide range of non-power benefits, 6 including fresh water storage, recreation, flood control, drinking water 7 supply, and irrigation. Hydroelectric projects also provide recreation 8 amenities such as boating areas, fishing sites, picnic grounds, and 9 hiking trails that enhance the quality of life for local communities. 10 PG&E hydro projects deliver water at 54 locations for consumption 11 by 39 different user groups. Reservoirs store about 2 million-acre feet 12 of fresh water, which represents 6 percent of the state’s total fresh water 13 storage capacity. PG&E hydro watershed lands provide recreation, 14 including 41 campgrounds, 37 picnic and day use facilities, for an 15 annual number of camp visitors of over 175,000. PG&E also leases 16 watershed lands for recreation home sites, marinas, resorts and parks, 17 boat docks, grazing, fish hatcheries, and tree farms. 18 C. Estimating Method 19 The Hydro Operations Program develops its forecast by subprogram and 20 MWC. Potential work is identified, categorized, and prioritized in hydro’s LTP 21 which provides a detailed schedule of work and associated expenditures into the 22 future. Subsequent planning iterations are used to review and refine the scope 23 of work and associated cost estimates as new information is available. The 24 most-current information for the following year (first year of the long-term plan) 25 serves as the basis for hydro’s annual budget forecast submitted for PG&E 26 management approval. PG&E’s management compares the Hydro Operations 27 Program to all other PG&E Programs prior to approving its budget. 28 Even after project-type work is included in the approved annual budget it 29 remains subject to final authorizations following review of more detailed 30 estimates, schedules, and justifications. Authorization to proceed is also subject 31 to an assessment as to whether higher priority work has materialized. The 32 expense and capital forecast in this GRC request and annual budget does not 33 include a contingency for unidentified work. Yet due to the age and location of 34 these assets, they are subject to unanticipated component failures and storm 3-12 (PG&E-3) 1 damage. Major storms disrupt operations and inflict considerable damage on 2 the water conveyance systems and even the powerhouses themselves. The 3 Hydro Operations Program manages these unplanned expenses, whether 4 expense or capital, by assessing what performance efficiencies can be captured 5 or lower priority work can be deferred so that funds are available to proceed with 6 the emergency work. This exercise occurs monthly and assures that the Hydro 7 Operations Program continuously optimizes the investment decisions needed to 8 ensure safe, reliable, and economic operations. 9 This chapter uses four sources of cost data to develop forecasts for 2007, 10 2008 and 2009. Actual expenditures are used for 2004. Hydro Operations’ 11 approved budget was used for the 2005 forecast. Hydro Operations’ 12 recommended budget was used for 2006 and the LTP provided the 2007 13 through 2009 forecast of expenditures. 14 1. Forecast Methodology 15 Hydro Operations’ centralized program management organizes the 16 forecast work by subprogram and MWC. Work identified within each 17 subprogram is compared to ensure similar standards and risk assessment 18 methodologies are used to prioritize work throughout the hydro system. 19 Hydro Operations planners—working with O&M personnel, engineers, 20 project analysts, and project managers—develop, review, rank, and submit 21 detailed funding requests to the Hydro Operations Program office for a 22 hydro wide comparison with all other work. The Hydro Operations Program 23 uses management’s collective experience and judgment to establish the 24 final assigned priorities and funding request. This recommended Hydro 25 Operations Program budget is then submitted to Generation’s management 26 to cross prioritize against the proposed fossil and nuclear budget requests. 27 This composite Generation request is then forwarded to the Utility for 28 comparison with all of the non-generation programs prior to approval. Hydro 29 Operations’ 2005 budget was approved in November 2004. 30 The Hydro Operation Program’s annual budget review results in a 31 ranked list of recommended work. The highest-priority work over the recent 32 past and through 2006 has been to maintain these generating assets to 33 operate safely, to protect the environment, to comply with all FERC license 34 conditions, meet other regulatory requirements and to operate reliably. As 3-13 (PG&E-3) 1 described in more detail below, the Hydro Operations Program forecast now 2 includes funding for efficiency improvements. PG&E’s 2003-2006 3 investments focused on long term reliable generation from these hydro 4 units. These investments are producing the desired results and therefore 5 Hydro Operations recommends investing in efficiency improvements that 6 provide customers with clean, carbon free, cost effective energy. Safety, environmental and regulatory compliance work will continue to 7 8 be assigned a higher budget priority. Efficiency improvements will be 9 compared to reliability work so that the highest value work, from a 10 customer’s perspective, is funded. This economic evaluation considers the 11 consequences of an in-service failure and captures the efficiency associated 12 with scheduling projects to reduce the combined outage duration. Hydro Operations’ LTP currently indicates minimal spending on 13 14 efficiency projects until 2006 or later. Most of this work, when it occurs, will 15 be integrated with reliability work to minimize outages. Hydro Operations’ 16 LTP does not include any capacity additions, although turbine efficiency 17 improvements may yield small increases (i.e., more energy produced with 18 the same water throughput). Hydro Operations’ 2003 thru 2005 budgets 19 included planning-related process improvements in the business 20 subprogram. In addition to minor expenditures to improve the LTP 21 database itself, Hydro Operations implemented new tools for gathering and 22 analyzing equipment condition assessment data, and also for analyzing and 23 scheduling work (“work management”). These process improvements 24 promote a systematic collection of data and subsequent analysis so that 25 future investments target the highest-value work. This improves PG&E’s 26 ability to assess which investments provide the highest value to customers. 2. Capital Forecast 27 PG&E forecasts an increase in capital expenditures in 2007-2009 so 28 that the hydro system can continue to provide low cost energy and ancillary services to customers for the long term. Figures 3-1[8] and 3-2 show the 29 30 [8] Figures 3-1 and 3-2 show capital expenditures for years 1990 through 2009. Actual expenditures are shown for 1990 through 2004 and forecast capital expenditures are for 2005 through 2009. 3-14 (PG&E-3) 1 reduced investment in the hydro assets following passage of 2 Assembly Bill (AB) 1890 in 1996 through PG&E’s bankruptcy filing in 2002. 3 It then shows the ramp up in expenditures consistent with funding 4 5 recommended in the 2003 GRC. Figure 3-1 shows nominal dollars whereas Figure 3-2 is in constant year 2005 dollars.[9] These two figures show costs 6 by subprogram starting in 1997 following PG&E’s conversion to SAP and 7 hydro’s current accounting structure. The cost data for 1990 through 2000 8 reflects the year the capital projects were completed or put into service. A 9 number of large multi-year projects approved prior to 1996 were completed 10 and put into service in 1997, which explains the higher total in that year. 11 The figures show capital expenditures for years 2001 through 2009. 12 Testimony in the 2003 GRC anticipated capital expenditures for maintaining 13 the hydro system would return to historic levels by 2005. Cost controls 14 including Hydro Operation’s use of its condition assessment program 15 focused expenditures on critical components in 2003 and 2004 and deferred 16 non-critical capital expenditures to later years. Hydro Operation’s forecast increase in capital expenditures from 2006 17 18 through 2009 is due to: 19 Requirement to implement new FERC license conditions, as discussed in Section D.3; 20 21 Reliability/availability projects deferred to later years as a result of 22 implementing Hydro Operation’s condition assessment program. These 23 projects have been phased into Hydro Operation’s LTP as discussed in 24 Section D.5. 25 Increased dam safety projects resulting from increased FERC and 26 DSOD focus and revised guidelines , as discussed under Section D.1; 27 and 28 Efficiency improvements and strategic issues as discussed in Section D.5. 29 [9] Figure 3-2 assumes approximately a 2.5 percent per year escalation to aid the reviewer in comparing dollars for this 5-year period. 3-15 (PG&E-3) Hydro Operation’s capital forecast consists of specific projects that are 1 2 individually reviewed to ensure that the highest priority work is identified and 3 funded first through PG&E’s budget process. The work papers supporting 4 this chapter provide details on all 2004 through 2009 forecast projects 5 greater than $1,000,000 and summary information on all of the smaller 6 projects included in the forecast. 3. Expense Forecast 7 8 Hydro Operation’s expenses include the costs of routine and ongoing 9 expenditures including the cost of personnel who operate and maintain the units. Figures 3-3[10] and 3-4 show Hydro Operation’s expenses from 1990 10 12 through 2009. Figure 3-3 shows nominal dollars whereas Figure 3-4 is in constant year 2005 dollars.[11] These two figures show costs by 13 subprogram starting in 1997 following PG&E’s conversion to SAP and the 14 current accounting structure. 11 15 The Hydro Operation Program has managed a flat expense budget 16 between 1997 and the 2004. This includes reduced expenses following the 17 18 1996 passage of AB 1890 and further reductions in 2000 and 2001 following passage of ABx1-6[12] and then PG&E’s Chapter 11 bankruptcy filing. A 19 closer review by subprogram reveals that the increased regulatory 20 compliance subprogram expenses have been offset by reductions in the 21 other subprograms. 22 Hydro Operation’s expense forecast is built upon its historic base 23 expenditures and specific expense projects as shown in Figure 3-5 for the 24 years 2000 through 2009. Routine base expenditures rise year over year as 25 a result of wage inflation and business drivers that increase the ongoing 26 workload. These routine expenditures decrease as a result of automation 27 and work process improvements that reduce the recurring workload. The [10] [11] [12] Figures 3-3 and 3-4 use actual expenditures for 1990 through 2004 and forecast expenses for 2005 through 2009. Figure 3-4 assumes approximately a 2.5 percent per year escalation to aid the reviewer in comparing dollars for this 5-year period. ABx1-6 repealed Public Utilities Code Section 216(h) and modified Sections 377 and 330(l)(2) prohibiting PG&E from selling any of its existing generating assets until at least January 1, 2006, and requires that those assets be dedicated for the benefit of California ratepayers. 3-16 (PG&E-3) 1 chart shows that other than the Regulatory Compliance Subprogram all 2 base costs are being held flat through the GRC forecast period. The specific business drivers that increase the forecast base and 3 4 project expenditures are: 5 discussed in Section D.3; 6 7 New regulatory fees imposed by State and Federal agencies, as discussed in Section D.3; and 10 11 Specific projects resulting from new environmental and safety regulations as discussed in Sections D.1 and D.2; and 8 9 New license compliance activities resulting from new FERC licenses, as Increased reliability/availability projects identified through condition 12 assessment and phased into the LTP as discussed in Section D.5. 13 Section D: Activities and Costs by SubProgram/MWC provides greater 14 detail including the workpapers where summary information is presented 15 for all 2007 through 2009 expense projects and a one page description is 16 included for all projects exceeding $1.0 million dollars. 17 D. Activities and Costs by Subprogram/Major Work Category 18 The six subprograms and 21 MWCs, (including the segregated regulatory 19 fees), managed under the Hydro Operations Program are listed in Tables 3-1 20 and 3-2 at the end of this chapter and are discussed in the order shown. Each 21 subprogram will be described in its entirety, addressing all of the expense 22 MWCs before describing capital MWCs. 23 1. Safety and Health Management Subprogram 24 25 a. General Safety is a higher priority for Power Generation. Power Generation 26 is committed to create and sustain a work and business environment 27 free of injury, illness, or property damage for the benefit of employees, 28 customers, and the general public. Achieving this value enables us to 29 be the low cost provider through decreased business losses and protect 30 the safety, health and well-being of our employees and the public. 3-17 (PG&E-3) 1 b. Expense (MWC HZ) Safety work was previously combined with environmental work. It is 2 3 now tracked separately to ensure priority is given to employee and 4 public safety. Base work in the safety subprogram consists of activities such as: 5 6 Industrial and Office Ergonomics training/evaluations; 7 Illness and injury prevention; 8 Health and wellness training; 9 Regulatory mandated training; 10 Training and re-certification for the safety staff; 11 Culture based safety process; 12 Asbestos and lead awareness training; 13 Safety-at-Heights Program; 14 Safe driving training; 15 First responder training – HAZWOPER; 16 Preparation of safety tailboards and department safety procedures; 17 Proper use of personal protective equipment; 18 Incident Investigations and communicating lessons learned; 19 Employee injury case management; 20 Safety performance recognition; and 21 Public safety awareness. 22 The base safety work forecast is based on historic expenditures. 23 The safety subprogram also includes funding for specific identified 24 projects that correct potential employee-related safety hazards, such as 25 arc-flash hazard remediation, ground grid studies and remediation, 26 penstock safety condition assessment and remediation, Helms fire 27 hazard reduction, fall protection guidelines and remediation, high 28 voltage protection remediation, and correcting other identified safety 29 hazards. 3-18 (PG&E-3) 1 c. Capital (MWC 13) Safety capital consists of specific facility safety projects essential to 2 3 keeping the public and employees and the environment safe in and 4 around PG&E’s hydro facilities. Figure 3-6 categorizes the capital costs 5 for this subprogram between 2001 and 2009. The forecast increase is 6 driven by the dam safety related projects. Forecast work planned under 7 this subprogram can be further categorized into the following six groups: 8 installations on trash racks, powerhouse cranes, penstocks, and 9 ladders to meet federal and state OSHA safety standards. 10 11 Fall Protection Work: This consists of safety-at-heights Arc-Flash Hazard Remediation: Employees are exposed to arc- 12 flash risks and in fact there have been serious injuries and in some 13 cases, fatalities in our industry. New regulations requiring 14 employers to provide protection against hazards associated with 15 electrical arc-flash events are either in place or imminent 16 (NFPA-70E was issued in 2004 and is expected to be adopted by 17 OSHA in early 2006). Power Generation is taking a pro-active role 18 to identify and control these hazards. Arc-flash hazards can be 19 generated during switching operations, grounding activities, or while 20 working on or near exposed energized equipment for all voltages 21 above 50 volts. Arc-flash hazard analysis for 31 hydro facilities 22 which will be completed by the end of 2005. This will result in 23 modifications to hydro powerhouse station service switchgear and 24 protection devices, administrative controls and/or personal 25 protective equipment control measures to ensure the safety of our 26 employees. 27 Ohio Brass Insulator Replacement Program: Hydro has 28 undertaken a program to replace certain high voltage insulators 29 manufactured by Ohio Brass Insulator Company. It was determined 30 that these insulators are faulty and have exhibited a high failure 31 rate, which poses an unacceptable safety risk to employees, 32 adjacent equipment and to system reliability. Replacement of these 33 insulators will mitigate a safety risk for employees who have to work 3-19 (PG&E-3) 1 around and under the structures where these insulators are 2 installed. The programmatic replacement was started in 2004 and 3 replacement of suspect Ohio Brass insulators at hydro facilities is 4 planned to be complete by 2008. 5 Dam Safety Work: Additional modifications are required because 6 of: (1) changing FERC and DSOD guidelines; (2) findings resulting 7 from FERC’s and DSOD’s regular facility inspections; and (3) the 8 FERC Part 12 independent analysis, under both normal and 9 emergency conditions, required every five years. These 10 modifications could improve the dam’s stability and operability, or 11 strengthen the low level outlet structures and spill gates. 12 A significant project is the Canyon Dam Outlet project. Canyon 13 Dam Outlet tower will be strengthened to conform with DSOD/FERC 14 guidelines. This includes upgrading the gates in the tower. 15 Additional details supporting the forecast are included in the work 16 papers. Additional dam safety work is forecast in the regulatory 17 compliance subprogram. This occurs when modifications are 18 required as a direct result of relicensing. 19 Penstock Safety and Life Extension Program: This includes 20 both relining and replacement of pipeline sections. Work on Hydro 21 Operation’s 89 individual penstocks (260,000 liner feet ranging in 22 age from 20 to105 years old), will begin in 2007 and will continue for 23 at least the next 20 years. A significant project is the Caribou 2 24 penstock realignment project. Engineering and permitting will occur 25 during the forecast period with construction contemplated for the 26 2010 to 2013 timeframe. This work will mitigate the slow hillside 27 creep of a penstock anchor block. Additional details are included in 28 the work papers. 29 Miscellaneous safety projects such as installing trash rack 30 debris-handling systems, improving personnel access to hydro 31 facilities, and correcting other identified safety hazards. 3-20 (PG&E-3) 1 2 3 2. Environmental Subprogram a. Expense (MWCs AK, ES, CR, AY) Environmental base work consists of environmental permitting and 4 compliance costs associated with the hydro facilities. This work 5 includes solid waste disposal and transportation, water quality 6 protection, environmental support for job planning, environmental 7 incident/emergency response, environmental plans and reports, 8 environmental risk management, and sensitive species protection. 9 Historic expenditures form the basis for the forecast of base work, 10 with adjustments made for new regulatory requirements related to air 11 quality requirements (e.g., diesel engines and anticipated new 12 regulations in the areas of water quality and habitat and species 13 protection). The Environmental subprogram also includes funding for 14 new environmental compliance activities, such as the Valley Elderberry 15 Longhorn Beetle (VELB) permitting and habitat species protection 16 Sensitive species and habitat protection expense costs for specific 17 hydro projects are included in the Regulatory section. Sensitive species 18 and habitat protection costs that are common, such as compliance with 19 a companywide permit for the protection of the Valley elderberry 20 longhorn beetle, are included in the Environmental Subprogram. These 21 costs are higher in the 2004–2006 time period to fund specific 22 conservation efforts, and will have leveled off in 2007. Costs are 23 anticipated to cover anticipated new species and habitat protection 24 requirements. 25 26 b. PCB Retrofit This work is near complete and has systematically reduced the 27 amount and concentration of PCBs in Hydro Operation’s equipment. 28 The remaining focus is removing PCBs from small equipment when it is 29 maintained. The PCB retrofit program also addresses equipment that 30 may be regulated when it is removed from service and considered 31 waste by the state. 3-21 (PG&E-3) 1 c. Lead Paint Management Program 2 This program ensures that the integrity of coatings on the hydro 3 facilities is intact. Each facility is reviewed, evaluated and addressed as 4 appropriate. 5 6 7 8 9 d. Oil Spill Prevention Program This program evaluates how to mitigate the potential for oil spills resulting from leaks in the turbine-generator bearing cooling systems. The work effort was divided into four phases: Phase 1, which was completed in 2004, identified the environmental risk associated with a 10 potential spill for the powerhouses located in PG&E’s watersheds. Each 11 site was evaluated and rated to determine the relative risk of oil spills in 12 general and identified the most “at risk” bearing systems. The sites 13 were categorized into five ”families,” whereby each family had several 14 common characteristics. The results were compiled into an extremely 15 detailed report and database. 16 Phase 2 developed detailed generic designs for each family of 17 units. The intent of the generic design was to step through the 18 engineering process to ensure that a practical and cost-effective 19 solution could be achieved and implemented for each type of cooling 20 system. Generic designs were completed for each family of units in 21 2005. 22 Phase 3 then took each family generic design and implemented a 23 “pilot” installation at a specific unit ranking high on the risk assessment 24 list and evaluated the effectiveness of the design approach from an 25 implementation and operation perspective. The intent was to take the 26 pilot installation data and any lessons learned and then select the best 27 remediation solution for each unit, on a careful and deliberate schedule, 28 which accounts for availability of resources and unit outage dates. To 29 date, three of the five generic designs have been converted to specific 30 designs (Pit 6 U1, Pit 7 U2, J.B. Black) and implemented. The final two 31 generic design conversions (Pit 4 and Volta) are expected to be 32 complete by the end of 2005. Critical performance data from each of 33 the pilot installations will be collected over a 6-month period to evaluate 3-22 (PG&E-3) 1 the effectiveness of the designs for system-wide installations. Phase 3 2 should be completed by early 2006. Phase 4, the final phase of the program, will implement the proven 3 4 solutions on a systemwide prioritized basis to reduce the risk to 5 acceptable levels. This phase will commence in 2006 and run past the 6 GRC forecast period. Two to four units will be retrofitted per year. Most 7 of the remediation will be classified as capital, however it’s expected 8 that the risk can be abated at some sites through minor expense 9 modifications and/or repairs. 10 e. Capital Costs for capital projects in the Environmental Subprogram include 11 12 costs to comply with water quality and air quality regulations, including 13 replacement of Helms sewage treatment plant and AG Wishon governor 14 sump tanks, various oil spill prevention projects, and replacement or 15 retrofit of diesel generators. 16 17 18 3. Regulatory Compliance Subprogram a. General The regulatory compliance subprogram addresses all of the 19 activities associated with obtaining and then maintaining the regulatory 20 approvals to own and operate PG&E’s hydro generating assets and 21 appurtenant facilities, including the associated state and federal fees. 22 Work in the regulatory compliance subprogram includes both expense 23 and capital work. Work that does not result in new capital assets is 24 treated in the expense category, and work that does result in new 25 capital assets is treated in the capital category. In many cases the work 26 is very similar in the expense and capital categories, with only the 27 outcome (a new capital asset or no new capital asset) distinguishing the 28 categories. 29 30 b. Expense (MWCs DL, DP and Regulatory Fees) As stated above, this subprogram includes expenditures for 31 regulatory required compliance activities that are not associated with a 32 new capital asset. These expenditures are classified under two MWCs: 33 (1) FERC hydroelectric license compliance activities (DL), and 3-23 (PG&E-3) 1 (2) license required recreational facility management activities (DP). 2 Regulatory fees are booked directly against the receiver cost centers 3 To provide context for existing and future business drivers, expense 4 work planned under Regulatory Compliance can be categorized into the 5 following five subcategories, as described in more detail below: 6 (1) complying with the conditions required by recently issued FERC 7 licenses and major license amendments; (2) complying with the 8 conditions required by anticipated new FERC licenses and major license 9 amendments; (3) compliance work related to facility safety; (4) other 10 compliance work associated with standard license articles or inspection 11 findings; and (5) state and federal fees imposed upon the hydro 12 generation assets. 13 Figure 3-7 shows the regulatory compliance subprogram expense 14 costs by MWC from 2000 through 2009. This subprogram is forecast to 15 grow by $14.9 million (73 percent) between 2003 recorded and 2006 16 forecast. This is $10 million more than forecast in the 2003 GRC. The 17 increase is primarily due to the expansive scope and complexity of the 18 license compliance measures included in the six new licenses received 19 between 2001 and 2003. 20 The regulatory compliance subprogram is forecast to increase an 21 additional $14.6 million in 2007. This is primarily due to the forecast 22 increase in license compliance work associated with accepting five new 23 licenses and two major license amendments in 2005 and 2006. There 24 are also some costs associated with new state and federal regulatory 25 fees, as described in more detail below. 26 1) Complying with the conditions required by recently issued FERC 27 licenses and major license amendments 28 FERC issued PG&E six new licenses and one major license 29 amendment between 2001 and 2005 (Haas-Kings, Mokelumne, 30 Rock Creek-Cresta, Pit 1, Hat Creek and Crane Valley new 31 licenses; and Potter Valley license amendment). Prior to this, the 32 last new license was issued in 1993. Relative to licenses previously 33 issued by FERC, the six recently-issued licenses contain more 34 extensive terms and conditions that require an expanded license 3-24 (PG&E-3) 1 compliance program to adhere to the new license requirements. 2 Moreover, the recently-issued licenses are each characterized as 3 “living documents” with extensive provisions for adaptive 4 management and similar measures that allow agencies and non- 5 governmental organizations (NGO) to actively participate in the 6 review and periodic revision of existing management prescriptions. 7 This includes requirements for extensive environmental studies and 8 long-term monitoring of the environmental effects of license- 9 required resource protection, mitigation and enhancement (PM&E) 10 measures. In addition to the adaptive management features of the 11 recently-issued licenses there are requirements for development, 12 maintenance, and operation of improved public recreation facilities 13 owned by a federal land management agency (typically the 14 U.S. Forest Service). 15 Illustrative of the complexity of the new “living” licenses and the 16 provisions for adaptive management are the approximately 17 200 additional compliance tasks associated with the six new 18 licenses issued since 2001. This includes concomitant 19 requirements for approximately 90 ongoing aquatic, terrestrial, 20 recreation, and cultural resource studies or monitoring efforts, at an 21 annual recurring cost of approximately $4,000,000 to $5,000,000. 22 PG&E has incorporated a number of measures to manage this 23 increasing license complexity, including assignment of focused 24 project management oversight upon receipt of the new license and 25 during the license implementation phase. This oversight provides 26 tight cost controls and periodic adjustments to forecast expenditures 27 for license implementation activities related to monitoring efforts. 28 Most of the expense compliance work is forecast to continue 29 30 31 32 beyond the 2007 to 2009 GRC. 2) Complying with the conditions required by anticipated new FERC licenses and major license amendments With five new licenses and two major license amendments 33 anticipated to be issued in the period 2005 through 2006, 34 (Spring Gap-Stanislaus and Kern Canyon new licenses and Bucks 3-25 (PG&E-3) 1 Creek major license amendment in 2005; Poe, Upper NF Feather 2 and Pit 3, 4 and 5 new licenses and Battle Creek major license 3 amendment in 2006), significant new expense compliance 4 expenditures are forecast for the period 2007 through 2009. These 5 new licenses and major amendments are for FERC hydroelectric 6 projects that are generally larger and more complex than the 7 recently-issued licenses and major amendments. However, PG&E 8 continues to capitalize on lessons learned from the preceding 9 relicensing efforts and implementation of the six recently issued 10 licenses. Building upon these lessons-learned, PG&E has entered 11 into agreements with stakeholders in three of the existing 12 relicensing proceedings and both of the major license amendment 13 proceedings which have helped to define and more closely 14 constrain the anticipated scopes of work associated with the new 15 licenses. 16 As a result, these anticipated new licenses are forecast to have 17 requirements for approximately 60 to 90 ongoing aquatic, terrestrial, 18 recreation, and cultural resource studies or monitoring efforts, at an 19 annual recurring cost of approximately $2,200,000 to $3,000,000. 20 As with the recently issued licenses (discussed above), the 21 anticipated new licenses will have extensive adaptive management 22 clauses written into the license conditions. The adaptive 23 management clauses will require periodic reassessment of 24 management prescriptions and provide opportunities for 25 government agencies and NGOs to adjust the PM&E measures, 26 (e.g., altering flow and reservoir storage regimes and monitoring 27 requirements). These anticipated new licenses will also require 28 active compliance management by PG&E and regular interaction 29 with various technical review committees comprised of agency and 30 NGO representatives. 31 The existing and anticipated new licenses also require expense 32 projects such as installation of rip-rap embankment reinforcements; 33 fishery habitat improvements; repair of deteriorating equipment such 34 as valves, weirs and spillways; and dredging. In addition, the 3-26 (PG&E-3) 1 anticipated new licenses will require extensive monitoring of stream 2 temperatures, fish and wildlife habitat, and other resource 3 protection, mitigation and enhancement measures. 4 3) Facility Safety Program – This work consists of an ongoing base 5 level of work and substantial additional required work and 6 expenditures resulting from new initiatives and requirements from 7 FERC and the DSOD 8 a) Base work consists of the following activities: 9 FERC Part 12 Inspection Reports – FERC requires that all 10 53 high and significant hazard dams in the PG&E system 11 be inspected every five years by an independent consultant. 12 There are typically 10 to 12 inspections every year. The 13 consultant reviews the accumulated surveillance data, 14 stability analyses, flood data, and seismicity data for each 15 dam and then conducts a physical site inspection. This 16 report, filed with FERC, recommends whether the dam is 17 safe for continued operations. The report may also 18 recommend modifications, subsequent additional field 19 investigations, analysis or increased monitoring activities. 20 Dam Surveillance Data Gathering and Reporting – PG&E 21 gathers and analyzes surveillance data such as leakage 22 weir readings, piezometer readings and optical surveys on 23 its dams and reports them on a quarterly basis with the 24 Department of Dam Safety (DSOD) and on a semi-annual 25 basis with FERC. 26 Emergency Action Plans – As required by the FERC, PG&E 27 has developed and annually updates its emergency action 28 plans. The annual update includes training of watershed 29 and centralized organization personnel, updating 30 emergency contact flow charts, and updating potential 31 failure scenarios and inundation maps as necessary to 32 incorporate results from updated analyses and surveys. 3-27 (PG&E-3) 1 Facility Safety Engineering Studies Requested by the FERC 2 and DSOD – Regulatory agencies may require additional 3 studies to confirm the safety or stability of various project 4 features as a result of new technical or industry information 5 (e.g., revised flood or seismicity data). These agencies can 6 request stability analyses, structural analyses of 7 appurtenant structures (e.g., radial gates), flood and 8 spillway studies. 9 10 b) Additional required work includes the following: New Part 12D Safety Inspection and Analyses 11 Requirements – FERC initiated new Part 12D Safety 12 Inspection Guidelines for Dams in 2003 that included new 13 performance monitoring reviews and new failure mode 14 analyses. These requirements apply to all of PG&E’s 53 15 “High” and “Significant” hazard potential classification dams 16 that are currently under Part 12D requirements. During 17 2003-2006, PG&E completed 43 separate Part 12D reports 18 including 37 updated to the new guidelines, and is 19 scheduled to complete 16 Part 12D reports during 2007- 20 2009 in conformance with these new guidelines. 21 Update all Dam Break Analyses and Flood Maps – FERC’s 22 Chapter 6 Guidelines requires inundation (i.e., flood) maps 23 to be included in Emergency Action Plans. The existing 24 inundation maps for all High and Significant hazard 25 potential dams were developed 20 to 25 years ago from 26 dam break analyses performed at that time. To meet the 27 new FERC guidelines, the Company will update all of the 28 dam break analyses and revise their associated inundation 29 maps starting in 2006 and ending in 2010. 30 Dam Safety Initiative for Rockfill Dams – PG&E’s dam 31 leakage monitoring program has recorded increased 32 leakage at PG&E’s concrete faced rockfill dams over the 33 past three years. PG&E, working in consultation with FERC 3-28 (PG&E-3) 1 and DSOD, has completed work at the Main Strawberry 2 dam in 2004 and Salt Springs dam in 2005. The concrete 3 joints and/or the upstream concrete faces have been 4 repaired at these two dams to reduce leakage back to early 5 historic levels. PG&E forecasts that a similar scope of work 6 will be required at all 13 of the Company’s rockfill dams, 7 with concrete facing repairs projected to be performed at 8 Relief, Courtright, and Wishon during 2006 to 2009; based 9 on the current and projected downstream leakage levels. 10 Review of Facility/Dam Security Measures and 11 Enhancements – As a result of the September 11 terrorist 12 attack, FERC has implemented a program to ensure that all 13 hydro licensee dams and facilities are adequately secured. 14 Additional inspection guidelines developed by FERC started 15 in mid-2002. Facility security and vulnerability assessments 16 were performed for PG&E’s hydro system in 2003. As a 17 result these assessments, the Company expects to develop 18 and implement additional security measures to improve 19 security and comply with the new FERC guidelines during 20 2004-2009. 21 New Pending FERC Guidelines on Evaluation of Water 22 Conveyance Systems and Dam Outlet Structures – FERC is 23 currently developing guidelines for evaluation of water 24 conveyance systems such as penstocks, canals, flumes, 25 and tunnels. PG&E expects by 2007 that these guidelines 26 will be enacted and the Company will be required to initiate 27 a program to evaluate the safety of these structures. PG&E 28 has proactively initiated a penstock safety program to 29 identify and mitigate risks and hazards and assure the safe 30 long term reliable operation of its penstocks. For this 31 reason, FERC has asked PG&E to help develop 32 appropriate industry-wide guidelines for these structures. 33 Prior to 2003, Geotechnical assessments of all penstocks 3-29 (PG&E-3) 1 were performed. Structural assessments and inspections of 2 the penstock pressure boundaries are planned for 2006 to 3 2008. PG&E is also embarking on a Canal Assessment 4 5 Program to improve the safe, reliable operation of 184 miles 6 of canals. The program will identify operational risks and 7 hazards along PG&E’s canals and develop measures to 8 mitigate unacceptable risks. The program will also develop 9 a tool to document canal conditions and predict future 10 maintenance requirements. This work was started in 2005 11 and is planned to be complete in 2009. FERC has also 12 taken a keen interest in this activity, as they plan to add 13 some requirements for open channel waterways to their 14 Engineering Guidelines sometime in the next five years. 15 Dam low level outlet rehabilitation projects are foreseen 16 in 2007-2009 based on DSOD/FERC mandated inspections 17 and assessments of various low level outlet features in 18 PG&E’s hydro system. 19 Coatings Program for All Gates – In conjunction with the 20 radial gate evaluation program implemented in 2003-2006 21 and the annual FERC and DSOD facilities inspections, the 22 Company has identified that the majority of the gates at 23 dams need new coatings to protect them from corrosion 24 and maintain structural integrity as well as to extend their 25 useful lives. The Gate Coatings Program has identified, 26 evaluated, and prioritized more than 130 gates in the hydro 27 system. The coatings work was initiated in 2004, some 28 performed concurrent with the radial gate repairs, and 29 continues through 2007. (13 gates in 2007.) 30 Dam Safety Instrumentation automation PG&E will start to 31 automate its dam safety instrumentation in 2007 to 2009 in 32 an effort to both gather more accurate and timely data and 33 analyze it in a more efficient manner. The data will be 3-30 (PG&E-3) 1 merged with hydro’s condition assessment database and 2 provide automatic trending, alarm, and report generation. 3 In addition, automation of data collection will provide real 4 time data that will provide a more realistic picture of actual 5 conditions within a particular dam during extreme events, 6 such as heavy storms or an earthquake, thereby offering a 7 greater assurance against dam failures and enhanced 8 public safety. 9 PG&E initiated the development of a formal dam inspection 10 program in 2005-2006 to assess and document the current 11 condition and identify any potential safety issues for all low 12 hazard dams not covered by FERC Part 12D or DSOD 13 inspections. This affects 121 dams in PG&E’s hydro 14 system. The initial round of assessments will take until 15 2010 to complete. 16 4) Other expenses associated with regulations, standard license 17 articles, inspection findings, and required public recreation program 18 a) Additional expense license compliance requirements can 19 materialize in any given year as a result of regulatory 20 inspections: 21 operations and facility safety; 22 23 26 27 Environmental and public use inspections by FERC every 3-5 years; and 24 25 Annual FERC and DSOD inspections focused on project Additional inspections scheduled in conjunction with major construction projects. b) Further expense requirements related to compliance with new 28 FERC regulations for exhibit drawings issued in 2004 is 29 expected to require substantial re-work of many drawings that 30 are part of existing or newly issued licenses, over the 2005 to 31 2009 time horizon. 3-31 (PG&E-3) 1 c) Public Recreation Program – Base work includes managing 2 campgrounds and day use areas; maintaining camp sites, 3 picnic tables, restroom facilities, and other equipment; 4 managing lands and roads at and surrounding recreation 5 facilities; and managing boat ramps, docks and other shoreline 6 recreation features. 7 License conditions may require development of shoreline 8 management plans or specific recreation facility improvements 9 or expansions to accommodate growing demand by the public 10 for water-oriented recreation opportunities. Where these 11 improvements or expansions are required at existing sites 12 owned by a federal land management agency (typically the 13 U.S. Forest Service), the associated construction costs are 14 treated as expense. 15 5) State and Federal regulatory fees imposed upon the hydro 16 generation assets. These regulatory fees are not captured under a 17 MWC, but are included as a separate cost category in the 18 Regulatory Compliance subprogram. These fees are forecast to 19 significantly increase as described below: 20 a) FERC Fees – Pursuant to Section 10(e) of the Federal Power 21 Act and Section 3401 of the Omnibus Budget Reconciliation Act 22 of 1986, FERC assesses annual charges against licensees and 23 exemptees of jurisdictional hydropower facilities to reimburse 24 the United States for the costs of administration of FERC’s 25 hydropower regulatory program [18 CFR11.1]. The annual 26 administrative costs are charged to and allocated among 27 licensees of projects of more than 1.5 MW of installed capacity. 28 The allocation is based on the authorized installed capacity of 29 pure pumped storage projects, such as the Helms Pumped 30 Storage Project, and on the authorized installed capacity plus 31 112.5 times the annual energy output in millions of 32 kilowatt-hours (kWh) for conventional projects, such as the 33 Haas-Kings River Project. 3-32 (PG&E-3) 1 The assessment of annual charges is based on an estimate 2 of the costs of administration of Part I of the Federal Power Act, 3 by FERC and other Federal agencies that are to be incurred 4 during the fiscal year in which the annual charges are assessed. 5 After the end of the fiscal year, the assessment is recalculated 6 based on the costs of administration that were actually incurred 7 during that fiscal year; the actual costs are compared to the 8 estimated costs; and the difference between the actual and 9 estimated costs is carried over as an adjustment to the 10 assessment for the subsequent fiscal year. The FERC and 11 other Federal agency fees have recently increased by about 12 10 percent per year on average as a result of Federal agencies, 13 both cultural and environmental, becoming more involved in the 14 hydro relicensing process. 15 FERC also fixes annual charges for the use, occupancy, 16 and enjoyment of U.S. lands, other than lands adjoining or 17 pertaining to dams or other structures owned by the United 18 States Government, or its other property [18 CFR11.2]. The 19 FERC sets annual charges, subject to adjustments, for the use 20 of government lands based on a schedule of rental fees for 21 linear rights of way established by the Forest Service. Annual 22 charges for transmission line rights of way are equal to the 23 per-acre charges established by the Forest Service for linear 24 rights of way. Annual charges for other project lands are equal 25 to twice the charges established by the Forest Service for linear 26 rights of way. Each year FERC updates its fee schedule to 27 reflect changes in land values established by the Forest Service 28 for linear rights of way. These charges have recently increased 29 by 2 percent per year on average. 30 Any licensee whose non-federal project uses a government 31 dam or other structure for electric power generation and whose 32 annual charges are not already specified in final form in the 33 license has to pay the United States an annual charge for the 34 use of that dam or other structure [18 CFR11.3]. Payment of 3-33 (PG&E-3) 1 such annual charges is in addition to any reimbursement paid 2 by a licensee for costs incurred by the United States as a direct 3 result of the licensee’s project development at such government 4 dam. Annual charges for the use of government dams or other 5 structures owned by the United States are 1 mill per kWh for the 6 first 40 gigawatt-hours (GWh) of energy a project produces, 7 1.5 mills per kWh for over 40 up to and including 80 GWh, and 8 2 mills per kWh for any energy the project produces over 9 80 GWh. The Narrows Project is assessed this type of 10 11 government dam charge each year. b) DSOD Fees – PG&E pays fees, based on dam height, to store 12 water at PG&E’s reservoirs. As a result of the State of 13 California budget crisis, DSOD‘s operating budget was 14 eliminated from the State’s General Fund and converted to fee- 15 based funding approach. Hence, a new fee structure was 16 imposed by DSOD in 2003/2004 to all dam owners to fully cover 17 their annual budget requirements. PG&E’s fee increased from 18 $174,240 to $756,750 annually; a 434 percent increase that 19 wasn’t included in Hydro Operations’ 2003 GRC forecast. 20 c) USGS Fees – PG&E pays fees to the U.S. Geological Survey 21 (USGS) for FERC required water data collection. PG&E’s 22 FERC licenses require that PG&E have an ongoing stream 23 gaging program in connection with its many hydro facilities 24 (conduits, canals, flumes, powerhouses, lakes, diversion dams) 25 for each of our licenses. FERC requires that that USGS 26 oversee this program and report any items of noncompliance 27 back to them. The USGS under FERC order requires that 28 PG&E's streamflow gaging compliance meets USGS standards 29 for measurement and record keeping. PG&E at its own 30 discretion with considerable cost savings for our customers has 31 chosen to have eight in-house hydrographers perform 32 streamflow measurements and collect the data ourselves to 33 USGS standards rather than pay for full measurement and data 34 collection service performed solely by the USGS. The annual 3-34 (PG&E-3) 1 fees to USGS include data review, field visits to verify 2 compliance with USGS standards, and publication/electronic 3 storage of the data. The annual USGS fees for PG&E’s FERC 4 required stream gaging requirements increases an average rate 5 of approximately 3 percent or about $8,000/year. 6 7 c. Capital (MWC 11) Capital work planned under capital Regulatory Compliance can be 8 categorized into the following four sub-categories, as described in more 9 detail below: (1) complying with the conditions required by existing 10 FERC licenses and major license amendments; (2) obtaining new 11 FERC licenses (relicensing) and those major license amendments; 12 (3) complying with conditions anticipated to be required by new FERC 13 licenses and those major license amendments; and (4) other 14 compliance work generally related to facility safety. 15 Figure 3-8 shows the cost of complying with the conditions in the 16 five new FERC Licenses and two new FERC license amendments 17 drives the subprograms costs. Greater detail on the specific projects 18 that make up this forecast can be found in the workpapers. 19 The company’s ability to forecast the cost of MWC 11 has greatly 20 improved since 2001 when the 2003 GRC was prepared. At that time, 21 the company had just received the first of six new licenses since 1993 22 and was just beginning to forecast the resulting capital compliance 23 costs. Also, the company had limited information as to when FERC 24 would issue the balance of the pending licenses (several of these 25 licenses had already experienced years of delay waiting for FERC to 26 act). Subsequently, in 2002, FERC implemented an aggressive 27 program to expedite issuance of long-delayed licenses and to avoid 28 future delays, such that license issuance dates can now be more 29 accurately forecast. Additionally, the company used the six new 30 licenses it received between 2001 and 2003 to benchmark and improve 31 its ability to forecast the cost of complying with the capital conditions of 32 future licenses. 33 34 Three other principal factors have affected actual costs for MWC 11 compared to the cost forecast in the 2003 GRC: (1) the time it takes to 3-35 (PG&E-3) 1 get permits approved to start compliance work after license issuance; 2 (2) the cessation of relicensing on the Kilarc-Cow Creek project 3 (a one-time event not anticipated at the time of the 2003 GRC); and 4 (3) uncertainty in the scope of Subcategory 4 work (the 2007 GRC 5 forecast subject to this uncertainty). These additional factors are 6 included in the 2007 GRC forecasts. 7 1) Complying with the conditions required by existing FERC licenses 8 9 and major license amendments After an eight-year period of no new licenses, extending back to 10 1993, FERC issued PG&E six new licenses and one major license 11 amendment between 2001 and 2005 (Haas-Kings, Mokelumne, 12 Rock Creek-Cresta, Pit 1, Hat Creek and Crane Valley licenses; and 13 Potter Valley license amendment). These recently issued licenses 14 and major license amendment contain terms and conditions with 15 which the company must comply to maintain the license. Relative 16 to licenses previously issued by FERC, they contain terms and 17 conditions that require more extensive capital work to meet the new 18 license requirements. The most costly capital work arising from the 19 recently issued licenses and major license amendments is typically 20 related to implementation of environmental enhancements (often for 21 flow release facility modifications or flow measurement facilities 22 related to increased minimum instream flow requirements) and 23 development of improved public recreation facilities. Formal project 24 management is used to cost-effectively plan and perform this work. 25 Most of the work from the six new licenses and one major license 26 amendment issued between 2001 and 2005 will have been 27 completed by 2007. 28 29 2) Obtaining new FERC licenses and those major license amendments Relicensing of the company’s 26 FERC-licensed hydro projects 30 as the current licenses approach their staggered expiration dates 31 represents a significant ongoing capital cost. The minimum 32 five-year duration relicensing process includes extensive 33 stakeholder involvement, performance of comprehensive natural 3-36 (PG&E-3) 1 resource studies, and balancing of complex societal and 2 environmental issues. 3 Presently, ten projects representing 1,509 MW of the 4 company’s 3,896 MW hydro generation portfolio, are in some phase 5 of relicensing (Spring Gap-Stanislaus, Kern Canyon, Poe, Upper 6 North Fork Feather River, Pit 3 4 5, Chili Bar, DeSabla Centerville, 7 McCloud-Pit, and Drum-Spaulding), and two more are involved in 8 major license amendments (Bucks Creek and Battle Creek). As 9 many as five of the projects presently in relicensing are anticipated 10 to be issued new licenses in the period 2005 through 2006 (Spring 11 Gap-Stanislaus, Kern Canyon, Poe, Upper North Fork Feather 12 River, and Pit 3 4 5), and both major license amendments are 13 anticipated to be issued in this same period. 14 Through this unprecedented volume of relicensing activity the 15 company has employed collaborative solutions to complex resource 16 issues. Using its collaborative approach to relicensing, the 17 company has been able to preserve the low-cost power generation 18 benefit for customers while substantially improving environmental 19 protections, public recreation opportunity, water quality, and other 20 beneficial uses of the project-affected resources. The company has 21 applied this same approached to the major license amendments. In 22 one ongoing relicensing proceeding (Kilarc-Cow Creek; 5 MW) 23 where a new license was anticipated to result in a higher than 24 market rate cost-of-production, the company entered into an 25 agreement with other stakeholders to discontinue relicensing of the 26 project, and instead, at an equal or lower overall cost to customers, 27 acquire replacement power and either transfer the project or 28 decommission it and restore the affected streams for salmon 29 habitat. Additionally, the company is one of seven hydropower 30 licensees across the nation making use of FERC’s new Integrated 31 Licensing Process (ILP), which will further improve the efficiency 32 and reduce the cost of relicensing. The ILP will become the default 33 relicensing process in mid-2005, and is being used on the three 34 newest of the Company’s ten ongoing proceedings. 3-37 (PG&E-3) 1 During the period 2007 through 2009, at least five hydro 2 projects representing 591 MW will be in some phase of relicensing 3 (Chili Bar, DeSabla-Centerville, McCloud-Pit, Drum-Spaulding, and 4 Merced Falls), with forecast expenditures representing 22 percent of 5 the capital expenditures under this subprogram. It is also 6 anticipated that a major portion of the capital cost of 7 decommissioning Kilarc-Cow Creek Project would be incurred 8 during this period. No other major license amendments are 9 anticipated to start during the 2007-2009 period. 10 11 3) Complying with the conditions anticipated to be required by new FERC licenses and those major license amendments 12 When issued, new licenses and major license amendments 13 contain terms and conditions with which the company must comply 14 to maintain the license. This capital work is typically related to 15 implementation of environmental enhancements (often for flow 16 release facility modifications or flow measurement facilities related 17 to increased minimum instream flow requirements), and 18 development of improved public recreation facilities. With up to five 19 new licenses and two major license amendments anticipated to be 20 issued in the period 2005 through 2006 (Spring Gap-Stanislaus, 21 Kern Canyon licenses and Bucks Creek major license amendment 22 in 2005 and Poe, Upper North Fork Feather River, Pit 3 4 5 23 licenses and Battle Creek major license amendment in 2006) and 24 two new licenses anticipated to be issued in the period 2007 25 through 2009 (Chili Bar in 2007 and DeSabla Centerville in 2009), 26 significant new capital compliance expenditures are anticipated 27 during the period 2007 through 2009. 28 The company has entered into comprehensive agreements with 29 stakeholders in three of the relicensing proceedings nearing 30 completion and both of the major license amendment proceedings, 31 which help define the anticipated scope of work. These agreements 32 improve PG&E’s ability to forecast the cost of this subprogram. 33 4) Other compliance work that results in new capital assets, generally 34 related to facility safety 3-38 (PG&E-3) This category includes miscellaneous regulatory required work, 1 2 including log booms and boat barriers, erosion control, facility 3 security, and other regulatory mandated enhancements. Most 4 facility safety improvements are included under MWC 13, Safety 5 and Health Management Program, since they address public safety 6 issues. However, those facility safety items that resulted from 7 FERC or DSOD inspections or specific directives are included in 8 this subprogram. 9 10 4. Operate Plant Subprogram a. Expense (MWC AW and EP) 11 Hydro Operations covers work at all hydro facilities. The switching 12 center operators remotely control, via Hydro’s Supervisory Control and 13 Data Acquisition (SCADA), the majority of PG&E’s generating units as 14 well as monitoring and control of PG&E’s vast dam and water 15 conveyance system. Many of the older and smaller plants require on- 16 site operator interaction for starting/shutdown of generators as well as 17 for real-time operational changes. Roving operators visit all the plants 18 on a routine basis and check for the vital signs of unit control, electrical, 19 and mechanical equipment and manage any deviations from expected 20 values to keep the units running at their optimum reliability and 21 performance. Typical readings would include: bearing oil levels, 22 generator winding temperatures, and water pressures. 23 Sixty-five of PG&E’s medium to large hydro units can be operated 24 semi-automatic or fully automatic. Fully automatic operation allows unit 25 start-up, shut-down and load changes to be made remotely via SCADA, 26 while semi-automatic operation only permits remote unit shut-down and 27 load changes. Seven major powerhouses—Pit 3, Pit 5, Caribou, Rock 28 Creek, Drum, Wise, and Tiger Creek—currently have no remote 29 operation capabilities since they function as area switching centers and 30 are therefore staffed 24 hours a day. This combined function results in 31 the current operating staff having to leave their switching center post to 32 manually make unit changes and adjustments to auxiliary systems. 33 Evaluations are underway to automate the remaining seven 34 powerhouses to ensure that PG&E continues to operate in full 3-39 (PG&E-3) 1 compliance of the increasing FERC license and CAISO powerhouse 2 operating requirements. 3 The new FERC licenses contain conditions that require complex 4 real time operations. The new requirements of unit ramp rate limits, 5 pulse flow releases, and variable minimum in-stream flows, require 6 precise control and coordination of station facilities within a river shed 7 with little margin for error. These requirements typically cannot be met 8 with existing monitoring and control systems which are beyond their 9 design life and what’s technically available. PG&E is pursuing facility 10 automation and integration as the more reliable and cost effective 11 solution over manual operation of the existing facilities with increase 12 staffing. 13 In addition, the CAISO demands for real-time load-following cannot 14 reliably be met with only manual operating capabilities. CAISO is 15 currently proposing to implement new settlement processes which will 16 severely penalize generators for deviations outside a relatively narrow 17 range around imputed schedules (plus or minus three percent of the 18 unit’s capacity, or 5 MW, whichever is larger). Avoiding penalties will be 19 a particular challenge during periods of non-steady state schedules, 20 including the prescribed ramp between different output levels in different 21 hours, or changes prompted by the CAISO’s automated dispatch 22 system. “Aggregation” of unit schedules on a watershed is being 23 permitted by the CAISO, and on average will reduce penalties due to 24 random schedule-following errors. However, taking full advantage of 25 schedule aggregation to minimize errors requires the ability to 26 simultaneously control all or most aggregated units on a watershed in 27 real-time, with great precision. 28 The existing plant auxiliary equipment and controls at these 29 seven powerhouses are at or near the end of their useful life and in 30 need of replacement. Their replacement will be integrated with the 31 planned 2006-2013 automation to reduce costs and improve watershed 32 control capabilities. 33 Automating the switching center powerhouses when combined with 34 the SCADA replacement projects makes switching center consolidation 3-40 (PG&E-3) 1 a real possibility. Two switching centers in the Shasta, DeSabla, and 2 Drum watersheds could be consolidated into one resulting in better 3 control of the watershed operations. The switching center 4 consolidations are forecast for the 2008-2011 timeframe. 5 All capital work resulting from automation and consolidation of the 6 switching centers will be captured under MWC 81, which is part of the 7 Maintain Reliability/Availability subprogram. 8 9 Operators prepare switch logs for equipment shutdowns and clearance, check the switch logs, and execute switching to actually clear 10 equipment. Other duties include both preparing and following 11 procedures to operate all plant equipment, canal systems, and 12 diversions dams. Additionally, operators are required to respond to 13 operational changes resulting from inclement weather conditions, both 14 during regular work hours and on an after-hour emergency basis. On 15 an ongoing basis, canals must be patrolled and valves/gates operated 16 to respond to changing water flow needs. 17 Operators must manage and document conditions and situations 18 such as in-stream flow releases and contractual water deliveries and be 19 primary responders for emergencies, as well as manage hazardous 20 waste. The hydro operations systems largely shut down automatically 21 when conditions warrant. Alarms may be activated by equipment 22 failure, storm activity, or interruptions to water flow. Operators are the 23 primary trouble shooters for failures in service. They respond to the 24 automatic alarms and recommend a remedy. They act on approved 25 recommendations or ask for assistance. When outages occur, usually 26 several weeks a year, operators assist maintenance crews with work 27 activities. Hydrographers measure and calibrate flow monitoring 28 stations and collect weather data. 29 Hydro Operations has specific operating plans for both winter and 30 summer operations. These plans take into account the unique weather 31 conditions that occur during these seasons, and the local topography in 32 each of Hydro Operation’s areas, and modify how the plants and water 33 delivery systems are operated to minimize the risk of damage to the 34 hydro facilities and thereby improve availability. By reducing the risk to 3-41 (PG&E-3) 1 facilities during times of heavy storms, savings are realized through 2 reduced storm damage to the facilities. During times of excessive heat, 3 stress on electrical system components increases dramatically. By 4 modifying operations during these times, savings are realized through 5 reduced equipment failures. 6 The working conditions are unique. Some locations are assessable 7 only by helicopter or boat. Hydro Operation’s employees work 8 weekends and holidays and respond to various changing operating 9 conditions and emergencies. They work on sloped grounds to inspect 10 dams, in confined areas, and around heavy plant equipment and 11 chemicals. They work on mountains and difficult terrains—often in 12 tunnels, small buildings, over rocks and gravel and large pipes, 13 suspended above flumes, on scaffolding, at remote sites, along steep 14 roads, in or near fast moving streams and rivers, in the snow, and 15 around poison oak, snakes, and spiders. They also maneuver on 16 flumes, around water and work around rotating and energized 17 equipment and noise. They use hand tools, electric and power 18 equipment, and computers. 19 Hydro Operations is planning to maintain recent operating practices 20 and staffing levels through 2009. This includes a staffing strategy to 21 manage attrition without temporarily increasing the number of 22 employees. Hydro Operations, like many other programs at PG&E, 23 forecasts a significant increase in employee retirements during 24 2005-2009, but believes it can manage attrition without undue operating 25 risk by utilizing the organization’s total capabilities. Hydro Operation’s 26 O&M personnel possess extensive knowledge of site conditions and the 27 unique operating characteristics because of their years of service. 28 Hiring a replacement in advance of the expected retirement would allow 29 the new employee to become knowledgeable about the hydro facilities 30 and complete approved apprentice programs. 31 The hydro organization has a blend of operating and maintenance 32 personnel, Title 200 under the IBEW contract, and construction 33 personnel, Title 300 under the IBEW contract. Hydro Construction’s 34 staffing levels increased in 2004 and 2005 as a result of the increased 3-42 (PG&E-3) 1 investment in maintenance and reliability projects. Hydro Operation’s 2 staffing strategy is to hire, train, and develop Title 300 employees to not 3 only handle the increase capital workload, but in anticipation of future 4 T200 vacancies. The goal is for these employees, with construction 5 experience from throughout the system, to have sufficient hydro 6 knowledge and experience to bid into the O&M positions without the 7 need for an overlap or temporary increase in staffing levels. The GRC 8 forecast assumes that this strategy will be successful and therefore the 9 O&M staffing levels and labor cost for this subprogram are flat. Hydro Operation personnel work closely with the Building and Land 10 11 Services department to manage the hydro lands as describe in Exhibit 12 13 (PG&E -2), Chapter 12, of this application. The Hydro Operation Program currently has approximately 140,000[13] of the 240,000 acres 14 managed by Building and Land Services. This includes approximately 15 65,000 acres of watershed lands surrounding the hydro production 16 facilities that are managed to ensure that there is no development or 17 activity adverse to hydro generation. This is reflected in PG&E’s 18 Corporate Policy Manual, Section E-5.10 that states: It is PG&E’s policy to manage company real property in a manner that supports the safe and reliable operation of company facilities, provides a positive environment for employees and customers, helps maintain and enhance environmental quality and biological diversity, maximizes the efficient use of energy, and promotes achievement of the company’s financial and service objectives. 19 20 21 22 23 24 5. Maintain Reliability, Availability and Improve Efficiency 25 26 Subprogram 27 a. General This subprogram includes work associated with maintenance of 28 29 powerhouse structures, turbine-generator and switchyard equipment, 30 dams, reservoirs, water conveyance systems, roads and bridges, and 31 other facilities. As described in the 2003 GRC, Hydro Operations 32 assessed how best to maintain long term reliability. The two key [13] Hydro makes use of approximately 168,000 acres of land. Approximately 26,500 acres are private or government land over which we have easements, licenses, use permits or other entitlements allowing their use for hydroelectric production. 3-43 (PG&E-3) 1 programs that support Hydro Operation’s maintenance work came from 2 the work management and condition assessment process improvement 3 projects initiated in 2001 and 2002. 4 (1) Condition Assessment Program 5 This program supports the proposed migration from time-based 6 maintenance to condition-based maintenance. The basis for the 7 current condition assessment program has been used for years to 8 develop priorities for asset maintenance and replacement. 9 However, much of the current asset management program is 10 time-based, meaning that asset maintenance or replacement is 11 being done based on time durations, with no certainty that it is 12 occurring at the optimum time for each asset. The advantage of a 13 state-of-the-art condition assessment program is its ability to use 14 condition-based assessments to determine when maintenance 15 should be performed or when an asset should be replaced. The 16 optimization of maintenance timing and asset replacement can 17 result in savings over the long run. The condition assessment 18 program system will standardize the collection and trending of 19 performance indicators for key components and facilities. 20 Performance measures or “out of spec” limits will be established for 21 critical components so that the appropriate corrective action is 22 triggered in the new work management System or long term 23 planning process. Condition assessment summaries will be 24 provided on both a powerhouse and systemwide level for overview 25 evaluations and prospective checks. Hydro Operations is faced 26 with maintaining equipment that in some cases is over 100 years 27 old. Condition assessment supports utilizing the right resources, at 28 the right time, on the right work. 29 Hydro Operations has had a basic condition assessment 30 program for years and 43 percent of 2004 projects resulted from 31 some form of condition assessment based upon visual, measured 32 values, fluid/gas sampling, or programmatic assessments. Our 33 current upgrades involve implementing an easily accessible 34 centralized repository for data and establishing uniform “out of 3-44 (PG&E-3) 1 tolerance” criteria to ensure that resources are efficiently allocated 2 to the highest value work. 3 Hydro Operations used the previous condition assessment 4 program to start implementation of a state-of-the-art condition 5 assessment program. This program will ultimately be used for 6 optimization of resources in Hydro Operations’ long term plan, 7 basing asset maintenance and replacement decisions on the 8 equipment’s condition, using developed performance measures. 9 In 2004, Hydro Operations started implementation of a cutting 10 edge software program which uses uploaded measured, visual, 11 physical (touch and smell), and calculated data to track equipment 12 condition. Out of tolerance criteria is being established for key 13 equipment as the software program is implemented. This software 14 database will enable Hydro Operations to centralize equipment 15 condition data, store a history of the equipment readings, allow for 16 trending the readings, and generate an alarm when readings vary 17 from pre-determined parameters. In addition, the condition 18 assessment program effort has a plan to review current equipment 19 testing procedures to ensure that testing is performed to industry 20 standards. 21 In the next few years, Hydro Operations will continue to expand 22 the implementation of the condition assessment program to include 23 additional facilities and equipment utilizing the software program, as 24 well as continuing development of “out of spec” criteria and 25 standardized testing procedures. 26 27 (2) Work Management Process The work management process improvement project, initiated 28 in 2001, reviewed Hydro Operations’ historic practices, identified 29 limitations, benchmarked other work management processes, 30 developed and mapped a new work management process and 31 developed an implementation plan. In 2004, a new work 32 management system (WMS), including new processes and tools, 33 was implemented to assist in managing not only the work on hydro 34 equipment and facilities, but also the resources available to perform 3-45 (PG&E-3) 1 the work. These new processes have now become ingrained as 2 part of the normal course of business for employees dealing with 3 hydro facilities. 4 The WMS facilitates the management of work to be performed 5 on hydro equipment by allowing each piece of identified work to be 6 assigned to a work center where it is planned, prioritized, and 7 scheduled for completion. Any identified work can be tracked, 8 whether it is periodic routine maintenance tasks, daily trouble 9 reports, minor or major equipment repair work, agency compliance 10 tasks or capital replacement projects. The system tracks the cost of 11 the work and the history of work done against the piece of 12 equipment. 13 The prioritization capability in the WMS allows Hydro 14 Operations to prioritize the work to assure the most critical 15 equipment needs are being addressed by the limited available 16 resources. 17 In addition to these two programs, progress with three additional 18 management processes, started in 2004, continues to ensure 19 projects are completed as planned within budget and on schedule. 20 21 (3) Improved Project Planning Hydro Operations recognized the significant increase in project 22 work that would take place during the catch-up period and the 23 increasing regulatory agency approval and permitting durations, 24 Hydro Operations therefore promoted use of a formalized a 25 multi-year project plan to ensure that projects would be completed 26 as planned. This multi-year project approach is composed of 27 planning and committing to complete the necessary engineering, 28 procurement of material, and obtaining of agency approvals and 29 permits in the first one-to-two years (depending on complexity and 30 lead times) and then completing the construction of the project in 31 the next two-three years. In order to achieve this approach, Hydro 32 Operations plans for projects in both the long-term plan and the 33 annual budgeting process in a manner that commits to completing 34 all phases of a project upfront and then provides the needed 3-46 (PG&E-3) 1 resources only in the year needed. By allowing additional time to 2 complete the engineering, procure the material, and obtain agency 3 approvals and permits, Hydro Operations can develop a more 4 dependable plan for use of construction resources and ultimately 5 complete the projects in the most cost-effective manner possible. 6 (4) Strategic Alliances 7 Hydro Operations also developed key strategic alliances with 8 outside engineering firms to efficiently contract out engineering work 9 while ensuring quality and cost competitive services. Hydro 10 Operations is currently in the process of also developing strategic 11 alliances with key major equipment suppliers, such as turbines, 12 large valves, generators, exciters, governors, SCADA, station 13 service switchgear, and switchyard equipment manufacturers. 14 15 (5) Project Management Hydro Operations continues to enhance its project management 16 capabilities, (organization created in 2003), to manage the larger, 17 more complex projects and outages. 18 b. Expense (MWCs AI, AX, AZ, BB and BK) 19 The hydro assets require substantial resources to maintain their 20 reliability. The forecast maintains the existing base maintenance 21 practices at historic expenditure levels but also includes a substantial 22 increase for specific new work to catch-up on investments not made 23 during the post AB1890 years. The increase for 2007-2009 is related to 24 projects that maintain unit availability and reliability and implement work 25 determined by programs started in 2003 as well as begins to capture 26 efficiency improvements as this equipment and systems are replaced. 27 Figure 3-9 categorizes this subprogram’s expenses by MWC. 28 It shows that costs increase across the board due to age and condition 29 of the hydro facilities, but that the greatest dollar increase is to MWC AX 30 (Maintain Reservoirs, Dams and Waterways). The following testimony 31 provides an expanded description of this work and specific expense 32 projects will also be included in the workpapers. 33 1. Water storage and conveyance projects – This work includes 34 additional reservoir and spill channel maintenance; canal, flume, 3-47 (PG&E-3) 1 and tunnel inspections and risk-based condition assessment and 2 repairs; and repairs to tailraces and stop logs. 2. Turbine-generator and associated equipment projects – This work 3 4 includes: (1) assessment and repairs to turbines, including runners, 5 wicket gates or needle valves, bearings, governors, and other 6 turbine components; (2) assessment and repairs of generators, 7 including field poles, bearings, cooler re-cores, and exciters; 8 (3) assessment and repairs of large valves, including penstock 9 shutoff valves, turbine shutoff valves, and pressure relief valves; 10 and (4) assessment and repairs to miscellaneous electrical 11 systems. 12 3. Infrastructure projects – This work includes increased maintenance 13 for buildings and roofing, roads, bridges identified in the Bridge 14 Mitigation Program, and telecommunication and SCADA facilities. 15 16 c. Capital (MWCs 81 and 5) Substantial capital expenditures are needed to maintain generation 17 reliability and availability and begin to capture increased efficiencies. 18 Figure 3-10 categorizes this subprogram’s work (described below) and 19 shows forecast increases in a number of areas. The forecast is based 20 upon specific identified projects which are listed in the workpapers 21 supporting this chapter including a one-page summary for each project 22 greater than $1 million. 23 (1) Water storage and conveyance projects 24 Water conveyance reliability, including canal, ditches, and 25 tunnel lining; flume replacement; spill gates replacement; 26 geotechnical slide mitigation; and installation of water 27 conveyance monitoring systems. 28 29 (2) Turbine-generator and associated equipment projects Turbine reliability and efficiency gains, including replacement or 30 upgrades of runners, seal rings, wicket gates, needle valves, 31 and associated turbine components. 32 33 Powerhouse large valves and mechanical auxiliary system reliability, including replacement of turbine shutoff valves, 3-48 (PG&E-3) 1 pressure relief valves, and penstock shutoff valves; governors; 2 and miscellaneous auxiliary oil, water, and air mechanical 3 systems. 4 Generator reliability and upgrades, including stator rewinds, 5 replacement of field coils and poles, and replacement of 6 excitation systems. 7 Supervisory Control and Data Acquisition (SCADA) and 8 telecommunication reliability including replacement of outdated 9 SCADA, analog radio systems, annunciators, and power sources. 10 11 Electrical Auxiliary Systems reliability, including replacement of 12 medium and low voltage switchgear, motor control centers, 13 transformers, and distribution systems; DC batteries, chargers 14 and distribution systems; emergency backup generator 15 systems; protection systems for generators, high voltage 16 transformers, and high voltage breakers; and plant 17 instrumentation and automation. 18 High Voltage Switchyard reliability, including replacement of high voltage breakers, switches, and step-up transformers. 19 (3) Infrastructure projects 20 This work includes capital replacement of buildings, roofing, 21 22 HVAC systems, road repaving, bridges identified in the Bridge 23 Mitigation Program, and telecommunication and SCADA facilities. 24 25 26 6. Business Subprogram a. Expense (MWC AB and BC) Base business subprogram work includes the administrative costs 27 associated with managing the Irrigation District contracts and the 28 reimbursable expenses incurred to perform maintenance on behalf of 29 the Irrigation Districts. The reimbursable maintenance expenses are 30 billed to the Irrigation Districts with the reimbursements recorded as 31 Other Operating Revenue and included in Exhibit (PG&E-2), 32 Chapter 16. It also includes initiating, managing and implementing 3-49 (PG&E-3) 1 business system improvements. The forecast is based on historic 2 expenditures and has decreased from 2005 due to the change in the 3 method used to record the Contract Services section costs. Beginning 4 in 2005, the Contracts section is allocated to the expense and capital 5 orders that they support 6 7 E. Translation of Program Expenses to FERC Accounts As discussed in Chapter 4 of Exhibit (PG&E-1) PG&E uses the SAP view of 8 cost information to manage program costs. Thus, for presentation in this GRC, 9 certain SAP dollars must be translated to FERC dollars. This is not an issue for 10 capital costs, where the SAP and FERC view are identical. For O&M expenses, 11 however, the SAP dollars include certain labor-driven adders such as employee 12 benefits and payroll taxes that are charged to separate FERC accounts and 13 addressed separately in this rate case. These labor-driven adders must be 14 removed from the SAP dollars for O&M expenses to present them by FERC 15 account. 16 Tables 3-3 through 3-8 show how the SAP expense dollars in the Hydro 17 Operations Program translate to the appropriate FERC accounts. The tables 18 show current year dollars (i.e., nominal dollars) and re-stated in base year 19 dollars (i.e., 2004 dollars). 20 21 F. Cost Tables PG&E’s capital and expense requests for the Hydro Operations Program 22 are summarized in the following tables: 23 Table 3-1 lists the subprograms and capital MWCs, showing 2004 recorded 24 capital expenditures and 2005 through 2009 forecast capital expenditures 25 by MWC; 26 27 Table 3-2 lists the subprograms and expense MWCs, showing 2004 recorded expenses and 2005 through 2009 forecast expenses by MWC; and 28 Tables 3-3 through 3-8 display the 2004 recorded expenses and 2005 through 29 2009 forecast expense expenditures by subprogram, MWC, and FERC 30 account. Each subprogram set of tables is in sequence by nominal dollars, 31 nominal dollars by FERC account and 2004 dollars by FERC account. 32 3-50 (PG&E-3) 1 2 3 4 FIGURE 3-1 PACIFIC GAS AND ELECTRIC COMPANY HYDRO CAPITAL NOMINAL ($000) $140,000 $120,000 Reliab./Avail./Prod. Regulatory Safety Environmental Base $100,000 $80,000 $60,000 $40,000 $20,000 $0 90-96 1997 1998 1999 2000 2001 3-51 2002 2003 2004 2005 2006 2007 2008 2009 (PG&E-3) 1 2 3 4 FIGURE 3-2 PACIFIC GAS AND ELECTRIC COMPANY HYDRO CAPITAL (2005 $000) $120,000 $100,000 Reliab./Avail./Prod. Regulatory Environmental Safety Base $80,000 $60,000 $40,000 $20,000 $0 90-96 1997 1998 1999 2000 2001 5 3-52 2002 2003 2004 2005 2006 2007 2008 2009 (PG&E-3) 1 2 3 4 FIGURE 3-3 PACIFIC GAS AND ELECTRIC COMPANY HYDRO EXPENSE NOMINAL ($000) 5 Business $180,000 Reliability & Availability Operate $160,000 Regulatory Environmental $140,000 Safety & Health Mgmt. Base $120,000 $100,000 $80,000 $60,000 $40,000 $20,000 $0 90-96 1997 1998 1999 2000 2001 2002 3-53 2003 2004 2005 2006 2007 2008 2009 (PG&E-3) 1 2 3 4 FIGURE 3-4 PACIFIC GAS AND ELECTRIC COMPANY HYDRO EXPENSE (2005 $000) Business $160,000 Reliability & Availability Operate Regulatory $140,000 Environmental Safety & Health Mgmt. $120,000 Base $100,000 $80,000 $60,000 $40,000 $20,000 $0 90-96 1997 1998 1999 2000 2001 2002 5 3-54 2003 2004 2005 2006 2007 2008 2009 (PG&E-3) 1 2 3 4 5 FIGURE 3-5 PACIFIC GAS AND ELECTRIC COMPANY HYDRO EXPENSE BASE AND SPECIFIC PROJECTS NOMINAL ($000) Specific Projects Base Business $180,000 Base Safety & Health Mgmt. Base Environmental $160,000 Base Regulatroy Compliance Base Operate Plant $140,000 Base Maintain Reliab. & Avail. $120,000 $100,000 $80,000 $60,000 $40,000 $20,000 $0 2000 2001 2002 2003 2004 6 3-55 2005 2006 2007 2008 2009 (PG&E-3) 1 2 3 4 5 FIGURE 3-6 PACIFIC GAS AND ELECTRIC COMPANY HYDRO CAPITAL SAFETY SUBPROGRAM (MWC 13) NOMINAL ($000) $20,000 Watershed Safety $18,000 Misc. Safety-Related Projects Dam-Safety Related Projects $16,000 Fall Protection $14,000 $12,000 $10,000 $8,000 $6,000 $4,000 $2,000 $0 2001 2002 2003 2004 6 3-56 2005 2006 2007 2008 2009 (PG&E-3) 1 2 3 4 5 FIGURE 3-7 PACIFIC GAS AND ELECTRIC COMPANY HYDRO EXPENSE REGULATORY COMPLIANCE SUBPROGRAM NOMINAL ($000) $60,000 MWC DP MWC DL Specific Projects Chili Bar license - July '07 MWC DL Base $50,000 Regulatory Fees Poe; Pit #3, #4, #5; Upper NF Feather River licenses - June '06 Potter Valley license amendment - Jan '04 Kern Canyon license Dec '05 $40,000 Crane Valley license - Sept '03 Spring Gap-Stanislaus license - Sept '05 Pit 1 license - March '03 Moke and RCC licenses - Oct '01 Hat Creek license - Oct '02 $30,000 $20,000 Haas-Kings River license - Jan '01 $10,000 $0 2000 2001 2002 2003 2004 2005 Year 6 3-57 2006 2007 2008 2009 $20,000 2000 2001 $30,000 2002 To Be Issued Prior Existing Relicensing Safety / Other $40,000 2003 6 3-58 2004 Year 2005 2006 2007 DeSabla Centerville license Chili Bar license Upper NF Feather River license Poe License Pit #3, #4, #5 Kern Canyon license Spring Gap-Stanislaus license Potter Valley license amendment Pit 1 license Crane Valley license Hat Creek license $50,000 RCC license 1 2 3 4 5 Mokelumne license Haas-Kings River license (PG&E-3) FIGURE 3-8 PACIFIC GAS AND ELECTRIC COMPANY HYDRO CAPITAL REGULATORY COMPLIANCE SUBPROGRAM (MWC 11) NOMINAL ($000) $60,000 $10,000 $0 2008 2009 (PG&E-3) 1 2 3 4 5 FIGURE 3-9 PACIFIC GAS AND ELECTRIC COMPANY HYDRO EXPENSE MAINTAIN RELIABILITY & AVAILABILITY SUBPROGRAM NOMINAL ($000) $80,000 Maint Other Equip (BK) Maint Generators (BB) $70,000 Maint Roads & Bridges (AZ) Maint Resv,Dams&Waterways (AX) Maint Gen Fac-Structure (AI) $60,000 $50,000 $40,000 $30,000 $20,000 $10,000 $0 2000 2001 2002 2003 2004 6 3-59 2005 2006 2007 2008 2009 (PG&E-3) 1 2 3 4 FIGURE 3-10 PACIFIC GAS AND ELECTRIC COMPANY MAINTAIN RELIABILITY & AVAILABILITY SUBPROGRAM (MWC 81) NOMINAL ($000) $70,000 $60,000 $50,000 $40,000 Miscellaneous Reliability Road Reliability Replacement of Batteries Structural installation/Removal Water Conveyance Reliability Modifications at Intakes/Dams Transformer Replacement Telecommunication Reliability Turbine Reliability Generator reliability Powerhouse Mechanical and electrical Reliability General Watershed Reliab/Availability $30,000 $20,000 $10,000 $0 2001 2002 2003 2004 3-60 2005 2006 2007 2008 2009