Water Supply Plan


21-1: Our understanding is that approximately 20,000 gpd of water will be consumed during natural gas usage. Is this both units or per unit? If water is delivered to the site by truck:

  1. How will it be stored on-site?
  2. How frequently will deliveries be made to the site (i.e., daily, weekly)?
  3. How many deliveries will be made during a given day?
  4. When will deliveries be made (morning, night, any time)?
  5. What traffic route(s) will be used?
  6. What type/size truck will be used?


21-2: What processes will be implemented to reduce water consumption during natural gas usage to 20,000 gpd? Will this be a combination of process cooling changes and wastewater recycling? Please explain in detail.

21-3: How much water will be required when oil is used as the fuel for one unit?  For both units?

21-4: Is the amount of water required for oil, more or less than what is required for natural gas? Please explain in detail.

21-5: Do the water saving measures that apply for natural gas, also apply to oil?

21-6: If the 2M gallon water storage tank is used when oil is the fuel:

  1. How much water per day will be consumed?
  2. How will the tank be refilled?
  3. In what timeframe will the tank be refilled?
  4. How many water deliveries per day will be needed?

21-7: Please explain in detail how the deionization ion system would work. Please specify what chemicals are involved, and in what amounts, how they will be delivered/stored/used at the site, and what steps you propose to take to protect workers, residents, and the environment from these chemicals.

22-3 Under the water plan, is it correct that Onsite water storage tank increased from 1,000,000 gallons (1 MG) to 2.25 MG? That is a 125% size increase, which in all likelihood, increases the footprint of impervious at the site. Please explain.

22-12 Under the water plan, is it correct that Johnston's signed agreement is dated 1/6/17 by the Mayor, which is 4 days before the Johnston Town Council authorized the Mayor to enter such an agreement with Invenergy? Do you believe this agreement is valid? Please explain.

22-13 Under the water plan, is it correct that Invenergy stated to the EFSB that 2 trucks per day on average will be needed to deliver water? However, Johnston's agreement indicates 3 trucks per day and up to 5 trucks per day will be needed on average to deliver water to the site. Do you agree that information to the EFSB needs to be amended accurately reflect which figure is correct? Please explain and amend as needed.

22-14 Under the water plan, is it correct that under the Johnston water agreement, CREC has allowed themselves a provision to alter its water consumption at any time? What if CREC decides to sell water 3rd party to another vendor, outside of their sole use? Do you agree that there is no provision in the agreement that would prevent you from doing so? Please explain.

22-15 What will happen if an oil operation event occurs more frequently, or lasts longer due to a gas shortage? All the events above indicate that in addition to the figures provided, a 3 truck a day rate is needed just to supply water in addition to the figures above. Do you agree? Please explain.

22-17 Please specifically identify and explain the status of the "all necessary permits and/or local approvals" needed as described in the last paragraph of 2.0 of the Water Supply Plan.

22-20 Has Invenergy requested PA consulting Group ("PA") to update its "monthly 20-year forecast (2019 through 2038) of the ISO-NE power market and a 20-year forecast (2019 through 2038) of PEC's operations and cash flows,"1 based on the revised Water Supply Plan filed with the EFSB on January 1, 2017? If not, why not? If so, please provide a copy.

22-29 Does the change in plant processes associated with the reduction in water usage have any impact on site and neighborhood safety? Please explain.

22-30 Please provide the identity and location of all power plants Invenergy or its subsidiaries (or other operators) operate with the newly proposed water/sewer saving technology to be incorporated into the CREC plant.

22-31 There is mention of summer time evaporative cooling usage at a rate of 4,600 gallons per hour (gph). There is limited mention of the duration for such an event (seldom during evenings, etc.), but no defined duration per event.

22-32 There are four (4) water balance diagrams showing different typical scenarios, but none of the scenarios include evaporative cooling usage.

22-33 Assuming a 3-day oil-fired event, as outlined in the report as a worst-case scenario, do you agree that approximately 2.2M gallons would be consumed?

22-48 What effect, if any, will the change in operating processes as set forth in the water plan have on data previously provided in the application and data responses? Please explain.

22-57 Is Johnston your one exclusive primary water source or are you still considering any other water sources?

22-58 What will you do if Providence refuses to allow Johnston to re-sell water to Invenergy?

23-2 Have you ever constructed a natural gas/oil fired electric generating facility of the size and magnitude of the CREC, whose process water demands were addressed with drinking water from a public water supply, delivered by truck, in the manner you are now proposing?

23-4 Have you ever constructed a natural gas/oil fired electric generating facility of the size and magnitude of the CREC whose miscellaneous low volume plant services such as general housekeeping, floor/equipment drains and general maintenance was supplied from the same process water, drained separately to a waste disposal tank, until removed from the property so as not to intermingle with the sanitary wastewater system?

23-5 Have you ever constructed a natural gas/oil fired electric generating facility of the size and magnitude of the CREC whose onsite potable water from domestic use was supplied by an onsite drilled well, with sanitary waste supplied by a separate onsite wastewater treatment system constructed on the property?