16-1 Water

Please provide details of the potential exposure to natural gas shortages that may require the proposed plant to utilize its onsite water supply and potentially have to use back up methods, such as trucking water.

16-1

Please provide details of the potential exposure to natural gas shortages that may require the proposed plant to utilize its onsite water supply and potentially have to use back up methods, such as trucking water.

RESPONSE

It is very difficult to quantify the potential exposure to natural gas shortages for Clear River Energy Center (“CREC”). Historical precedent for shortages have shown them to be infrequent and of short duration. If Invenergy Thermal Development LLC (“Invenergy”) observes plants in the New England (“NE”) area that have duel fuel capabilities of similar size to CREC, their average maximum consecutive hours that they ran on fuel oil in 2014 and 2015 was 72 hours and 68 hours respectively. There are however several reasons why Invenergy believes these numbers are higher than we would expect for CREC:

1)         CREC is located directly on the Algonquin main line and closer to the natural gas supply source then the plants included in this historical analysis.

2)         The information to assess whether a gas shortage has occurred is not readily available. As such, in this analysis it was assumed that the use of fuel oil coincided with a natural gas shortage event. In reality, fuel oil can be used for other reasons such as for maintenance or for a plant located on a lateral or at the end of a lateral if gas capacity was not available. Therefore, it is our expectation that the maximum consecutive hours based on natural gas shortages would be lower for CREC.

3)         Pipeline infrastructure projects such as Atlantic Bridge and Spectra’s AIM project will increase the availability of gas supply to NE gas power generators and reduce the severity of natural gas shortages.

Accordingly, Invenergy has designed our water systems to include an appropriate level of water storage capacity on site to allow for continued operation on fuel oil for these short duration natural gas shortages and do not anticipate a need for a backup water supply that would be trucked to the site.

 

RESPONDENT:

 

John Niland, Invenergy Thermal Development LLC

DATE:

August 25, 2016