Blasts / Explosions

17-1     Is there any possibility, no matter how small, that there could be an explosion at the Spectra/Algonquin compressor station which could cause an explosion at the Invenergy plant?  If it is your opinion that this is impossible, please explain.  If it is your opinion that it is in any way possible, please explain the conditions under which this could occur, the likelihood of this occurring and your reasoning.  Also, if this is possible, no matter how unlikely, please calculate the size of the blast area that would be affected by such an explosion.

17-2     Is it at all possible that a problem at the Invenergy plant could cause an explosion at the Spectra/Algonquin compressor station?  If it is your opinion that this is impossible, please explain.  If it is your opinion that it is in any way possible, please explain the conditions under which this could occur, the likelihood of this occurring and your reasoning.  Also, if this is possible, no matter how unlikely, please calculate the size of the blast area that would be affected by such an explosion.

17-3     Please explain/calculate the probability of a certain blast events occurring, including the Algonquin Station exploding, the hydrogen storage tubes or generator igniting, and/or the proposed CREC facility itself exploding.

17-4     Please conduct an ALOHA (Area Locations of Hazardous Atmospheres (“ALOHA”) Model developed by the EPA and the National Oceanic and Atmospheric Administration) analysis to determine the extent of the impact area of any possible explosion at the Invenergy facility and/or the Spectra/Algonquin facility, no matter how remote the possibility.