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ELECTRICITY RESTRUCTURING ROUNDTABLE. Resolving Dual-Fuel Capability & Environmental Permitting Issues. Edward Kunce Deputy Commissioner Mass DEP 9 December 2005. FROM MASS DEP's PERSPECTIVE UNCONTROLABLE FACTORS IN CONTINGENCY PLANNING. NATURE Gulf Coast hurricane damage
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ELECTRICITY RESTRUCTURING ROUNDTABLE Resolving Dual-Fuel Capability & Environmental Permitting Issues Edward Kunce Deputy Commissioner Mass DEP 9 December 2005
FROM MASS DEP's PERSPECTIVE UNCONTROLABLE FACTORS IN CONTINGENCY PLANNING • NATURE • Gulf Coast hurricane damage • Winter 2005/2006 • ECONOMICS • Relative costs of gas vs. oil • ISO’s dispatching and bidding processes • Fuel purchasing strategies • INFRASTRUCTURE AND OPERATIONS • Ability to deliver fuel driving “cold snaps” • Facility limitations for fuel oil, e.g. storage capacity • O&M factors with fuel switching • Satisfying demand of other fuel oil users • LAS VEGAS • Differing/Contradictory projections on Fuel Shortfalls “which one you betting on??
MANY "SPECIES" OF GAS FIRED POWER PLANTS • Gas only • Permitted for dual fuel but only use gas • Permitted for dual fuel and use both fuels (primary gas, 30(+)days oil)
DUAL FUEL POWER PLANTS FRAMEWORK FOR MASS DEP's CONTINGENCY STRATEGY • Balance economic and environmental risks • Work within existing regulatory framework as much as possible • Build off historic fuel oil use patterns
DUAL FUEL POWER PLANTS UNDER REVIEW • Pittsfield Power 173 MW • Dartmouth Power 67 MW • Mass Power, Springfield 270 MW • NEA Bellingham 327 MW • W Springfield GT 94 MW • Mirant Kendell (*) 168 MW Total 1099 MW (*) began compliance testing to burn oil Nov. 05
FUEL OIL USE AT DUAL FUEL POWER PLANTS
MASS DEP's PROPOSED STRATEGY • Meet with dual fuel power plant representatives • Clarify flexibility in existing permits & regs. • Review past fuel oil use • Review infrastructure limitations/issues • Review expected fuel oil use this year • Attempt to get agreements on voluntary “set-aside” • Plan for a number of “cold snap shortfalls” • Facilities “set-aside” some of permitted days for “cold snap shortfalls” • Be prepared for emergency regulations if Items 1&2 aren’t adequate
DATA TO SUPPORT "SET-ASIDE" STRATEGY • Assumes three “cold snaps” during the winter that last an average of three days each and that these cold snaps coincide with NG shortfalls that • would require dual fuel facilities to burn oil or shut down. These facilities would serve as peaking facilities for about 12 hours each “cold snap” day. • (This results in 4.5 days set aside for cold snaps) • 2. “Balance” represents operating flexibility within existing permits for oil use assuming a baseline use established by max use of last four years • plus “cold snap” set-aside.