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Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14, 2014

Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Page 1: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

Gas-Electric System Interface Study

Target 4

Fuel Assurance:

Dual-Fuel Capability v. Firm Transportation

November 14, 2014

Page 2: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Acknowledgement and Disclaimer

The EIPC appreciates and acknowledges the support of DOE for the Eastern

Interconnections Studies Project

Acknowledgement:

This material is based upon work supported by the Department of Energy, National Energy Technology

Laboratory, under Award Number DE-OE0000343.

Disclaimers:

This report was prepared as an account of work sponsored by an agency of the United States

Government. Neither the United States Government nor any agency thereof, nor any of their employees,

makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy,

completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents

that its use would not infringe privately owned rights. Reference herein to any specific commercial

product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily

constitute or imply its endorsement, recommendation, or favoring by the United States Government or

any agency thereof. The views and opinions of authors expressed herein do not necessarily state or

reflect those of the United States Government or any agency thereof.

Page 3: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Agenda

Overview of Target 4 research goals

Specific analyses

• Simple Cycle and Combined Cycle Storage Capability

• Dual-Fuel Operating Characteristics and Costs

• Oil Market Availability and Resupply Options

• Fuel Switching Design and Practice

• Economic Tradeoffs between Dual-Fuel v. Firm

Transportation

Q&A

Page 4: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Target 4 Study Limitations

Fuel assurance from PPAs’ perspective

No quantification of wholesale energy price effects with

Firm Transportation v. Dual-fuel capability

Other factors affecting generators’ willingness to invest

in Firm Transportation

• Different performance on gas v. ULSD

• Profit margin from incremental energy sales

• Increased permitting difficulty to store and burn ULSD

• Penalty avoidance as a capacity resource

Page 5: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Target 4 Highlights

Page 6: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Primary Findings

Going forward, new gas-fired plants are expected to use

ultra low sulfur diesel (ULSD) as the primary back up

fuel

Anticipated heavy reliance on ULSD represents a major

change in the distillate oil market

• ULSD supply chain is robust

Air permits typically cap oil use to 720 hours, but some

permits have established lower annual hourly limits

At most locations, the cost of dual-fuel capability is

much less expensive than the incremental cost of firm

transportation to satisfy the fuel assurance objective

Page 7: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Target 4 Approach

Identify constrained locations across the Study Region

from Target 2 Frequency – Duration results

Define gas turbine technology types in Simple Cycle

(SC) and Combined Cycle (CC) mode

Design cost model to account for regional differences in

dual-fuel capability, firm transportation (FT)

• Account for non-firm transportation costs

• Account for local facility improvements where applicable

Develop a flexible financial modeling tool that can be

updated by the PPAs in response to changing market

and operational dynamics

Page 8: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Current Dual-Fuel Capability

Liquid Fuel Storage and Resupply Methods

• Focus on backup fuel storage capacity and backup fuel

consumption at full load

• Data on resupply/delivery logistics

Data pieced together from public and confidential data

sources, i.e., PPAs, generators, air permit applications,

U.S. EPA

Database contains consistent storage and fuel use

data for 52 units (CTs and CCs)

• Unit-specific details will not be published

Page 9: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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CT Characteristics & Costs

Focus on differential performance and cost for

• Single Fuel (natural gas)

• Dual-Fuel (natural gas and ULSD)

Selected CT models representative of recent and near

future new SC and CC plants

• Heavy frame units using “F” technology:

◦ GE 7FA (7F.05)

◦ Siemens SGT6-5000F

• Aero-derivative units:

◦ GE LM6000

◦ GE LMS100

Page 10: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Information Sources

Review and reliance on 2014 PJM CONE Study • Capital and operating cost account structure

◦ SC and CC 7FA-based plants

◦ Single fuel and dual-fuel cost estimates

• Cost adjustments for multiple locations ◦ Labor cost

◦ Property, sales, and income taxes

◦ Environmental regulation

Review and reliance on 2013 NYISO CONE study • Capital costs for LMS100 SC

◦ Single fuel and dual-fuel configurations

◦ Different site conditions, including NYC/LI

Fuel storage tank construction cost information from

NYSERDA study prepared by ICF

Discussions with CT manufacturers

Page 11: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Cost Models

Cost models developed for incremental dual-fuel

capability

• Three plant types

◦ Standard CC plant (2x1 7FA)

◦ Heavy-frame SC plant (2 x 7FA, no SCR)

◦ Aero-derivative SC plant (2 x LMS100, with SCR)

• Location-specific parameters

◦ Labor cost factors

◦ Taxes (sales, property, income)

◦ NOx limitations (attainment v. non-attainment zone)

◦ Liquid fuel inventory and tankage requirements

• Capital cost and fixed operating cost differentials

Page 12: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Dual-Fuel Capital Cost for 2x7FA CC Location Base RTO EMAAC SWMAAC WMAAC Dominion

Locational Assumptions OH OH NJ MD PA VA

Nominal Capital $MM for 2018 CO

Gas Turbine Scope $4.700 $4.700 $4.700 $4.700 $4.700 $4.700

Other major equipment $0.000 $0.000 $0.000 $0.000 $0.000 $0.000

Other construction labor $0.000 $0.000 $0.000 $0.000 $0.000 $0.000

Liquid Fuel, Demin water handling (Mat'l) $0.900 $0.900 $0.900 $0.900 $0.900 $0.900

LIquid Fuel, Demin water handling (Labor) $0.900 $0.900 $1.170 $0.887 $0.920 $0.804

Liquid fuel storage tank (Mat'l) $0.827 $0.827 $0.846 $0.843 $0.825 $0.838

Liquid fuel storage tank (Labor) $0.556 $0.556 $0.740 $0.559 $0.568 $0.504

Demin water storage tank (Mat'l) $0.498 $0.498 $0.498 $0.498 $0.498 $0.498

Demin water storage tank (Labor) $0.335 $0.335 $0.436 $0.331 $0.343 $0.300

Incremental Land for Tanks $0.038 $0.038 $0.066 $0.074 $0.042 $0.054

Startup Testing ULSD $5.087 $5.087 $5.244 $5.217 $5.070 $5.179

Startup Testing Energy Sales on ULSD ($1.611) ($1.611) ($1.812) ($1.647) ($1.605) ($1.636)

Inventory carrying cost as O&M $0.000 $0.000 $0.000 $0.000 $0.000 $0.000

Total Incremental Direct Cost $12.232 $12.232 $12.788 $12.362 $12.261 $12.142

Sales tax on equipment and materials $0.416 $0.416 $0.488 $0.418 $0.413 $0.434

EPC Fee $1.096 $1.096 $1.173 $1.096 $1.100 $1.077

EPC Contingency $1.023 $1.023 $1.095 $1.023 $1.027 $1.005

Development Cost $0.563 $0.563 $0.602 $0.563 $0.565 $0.553

Mobilization & Startup $0.113 $0.113 $0.120 $0.113 $0.113 $0.111

Non-fuel Inventories $0.056 $0.056 $0.060 $0.056 $0.056 $0.055

Owner's Contingency $0.332 $0.332 $0.331 $0.343 $0.331 $0.339

Financing Fees $0.380 $0.380 $0.400 $0.383 $0.381 $0.377

Indirect (factored) Costs $3.977 $3.977 $4.271 $3.996 $3.986 $3.951

Total Overnight Cost $16.209 $16.209 $17.059 $16.357 $16.247 $16.093

Total Installed Cost $17.765 $17.765 $18.697 $17.928 $17.806 $17.638

Installed Cost per kW of ICAP $27.29 $27.29 $27.99 $27.00 $27.44 $26.72

Page 13: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Dual-Fuel O&M Costs

CT Model and Configuration 2x1 7FA CC 2x7FA SC 2xLMS100 SC

Location Base Base Base

Locational Assumptions OH OH Newburgh

Annual Fixed O&M Cost (2018 $MM /yr)

Materials & Contract Services $0.118 $0.044 $0.011

Administrative & General Expense $0.023 $0.047 $0.011

ULSD for Regular Testing $1.060 $1.070 $0.491

Energy Offset for Testing ($0.336) ($0.223) ($0.116)

Property Taxes $0.259 $0.303 $0.068

Insurance $0.107 $0.126 $0.054

ULSD Inventory Carrying Cost as Fixed O&M $0.203 $0.206 $0.094

Total Fixed O&M (2018 $MM/yr) $1.435 $1.572 $0.612

Total Fixed O&M (2018 $kW-yr) $2.20 $4.08 $3.32

Page 14: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Fuel Oil Market Assessment

Continued discussions with generators re backup fuel

issues

• Going forward most backup fuel use will be ULSD

• Reduction in seasonal supply constraints

• Some constraints on supply reported for last winter

◦ Weather conditions affecting deliveries by truck

◦ Confusion between low sulfur diesel and ULSD

Data from refiners, suppliers and distributors re

availability, costs, and storage issues

• Some storage and use considerations, i.e., lubricity and

microbiological contamination

• Treatment with additives and biocide applications to

storage tanks

Page 15: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Fuel Switching (Manufacturer View)

Fuel switching capability is common design option

Switching can be “on the fly”

• Frame units drop load (e.g. 80%) to switch

• Easier for aero-derivatives (e.g. LMS100) to switch at

100% load

Entire process takes a few minutes if systems ready

• Liquid fuel systems are on stand-by (recirculating

between tank and CT)

• Water injection systems (not required for gas firing)

Switching can be automatic (based on delivery

pressure signal) or operator-initiated

Page 16: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Testing of Switchover Capability

Regular testing of liquid fuel systems

• Testing does not require a 100% switchover

• Liquid fuel only needs to be fired for a few minutes

• Long-term service agreements which guarantee

emissions may require weekly testing

Water injection for heavy frame CTs on liquid fuel

• Needed to meet NOx limits

• Additional equipment to maintain in ready status

• Additional extreme cold-weather concerns

Page 17: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Fuel Switching – Operator View

Operator (Genco) Perspective: Costs & Benefits

Reasons for periodic oil operation

• Reliable switching requires training and practice

• Service Agreements may require testing to maintain oil

firing and emission guarantees

• Fuel and water systems tested and ready

• Operator training critical due to frame CT complexities

Benefits of periodic oil operation

• Systems and operators ready if called upon

• Less chance of trip or emission excursion

Costs of periodic oil operation

• High ULSD price relative to LMPs

• Higher maintenance accrual rate is not an issue

Page 18: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Fuel Switching – Operator View (2)

Operator (Genco) Perspective: Would Periodically Test

on Oil if Costs Were Recoverable through Tariff

Fuel switching practices

• GTs can run at reduced load if gas pressure drops

• If need to switch, GT load reduced to minimize chance of

trip and avoid emission exceedance

• Problems with oil and water systems in cold weather

• GTs injecting water for gas are less vulnerable

• Switching virtually always by operators; seldom

automatic

Gencos do not test / practice on oil

• Costs > benefits (higher chance of successful switch)

• Inadequate financial incentive to test on oil

Page 19: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Dual-Fuel v. Firm Transportation

27 constrained locations selected by PPAs

• Target 2 Frequency – Duration results

• Focus on areas where new development likely

Natural gas supply and delivery by location

• Identification of pipeline path from a production basin to

plant location

• FT reservation rates (incremental), avoided IT costs

• Lateral as proxy for LDC upgrade costs, if applicable

• Net Cost of FT

◦ FT rate less the avoided cost associated with non-firm

transportation costs

Page 20: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Net Cost of FT

$0

$10

$20

$30

$40

$50

$60

$70

$80

$90

$100

Cen

tral

CT

SW C

T

Cap

e C

od

SE M

A

Mai

ne

New

Ham

psh

ire

Ver

mo

nt

NYC

Lon

g Is

lan

d

Low

er H

ud

son

Val

ley

Cap

ital

Dis

tric

t

Up

per

Pen

nin

sula

Twin

Cit

ies

Sou

ther

n Il

lino

is

Do

min

ion

No

rth

PEP

CO

BG

E

Del

mar

va

PEC

O

PSE

G N

ort

h

PSE

G S

ou

th

Mau

ry E

ast

Co

lber

t

Joh

nso

nvi

lle

Sum

mer

Sh

ade

Cen

tral

East

ISONE NYISO MISO PJM TVA IESO

Net

FT

Rat

e (

$/m

on

th p

er

Dth

/day

) Combined Cycle

Simple Cycle

Page 21: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Components of Net Cost of FT

($40)

($20)

$0

$20

$40

$60

$80

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

Central CT SW CT Cape Cod SE MA Maine New Hampshire Vermont

Leve

lize

d $

/mo

pe

r D

th/d

ay

Avoided ITCost

Lateral FTCost

Pipeline FTRate

Net FT Cost(Base CF)

Net FT Cost(CF = 0%)

Net FT Cost(CF = 25%)

Net FT Cost(CF = 50%)

Net FT Cost(CF = 75%)

Net FT Cost(CF = 100%)

Note: Vertical axis scale varies for each PPA.

Page 22: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Dual-Fuel v. Firm Transportation

ULSD Logistics by Location

• Identification of depot

• Identification of transport mode (truck or barge)

• Estimation of normal delivery lag (order to receipt)

• Estimation of potential weather delays (snow, ice)

• Net price based on rack price, shipping, demurrage

Target Inventory and Fuel Storage Tank Volume

• Expressed in days of full load burn

• Location-specific variables

◦ Severity of natural gas delivery constraint

◦ Delivery lag and potential weather delay

◦ Expected capacity factor when operating on ULSD

◦ Tank volume allowance for “lumpy” barge delivery size

Page 23: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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ULSD Tank Capacities by Location

0 2 4 6 8 10 12

Central CT

SW CT

Cape Cod

SE MA

Maine

New Hampshire

Vermont

NYC

Long Island

Lower Hudson Valley

Capital District

Upper Penninsula

Twin Cities

Southern Illinois

Dominion North

PEPCO

BGE

Delmarva

PECO

PSEG North

PSEG South

Maury East

Colbert

Johnsonville

Summer Shade

Central

East

ISO

NE

NY

ISO

MIS

OP

JMTV

AIE

SO

Days of Full Load Fuel Burn

Combined Cycle

Simple Cycle

Page 24: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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ULSD Tank Capacity Drivers

0

1

2

3

4

5

6

7

8

2x1 GE 7FA CC 2 x LMS100w/SCR

2x1 GE 7FA CC 2 x LMS100w/SCR

2x1 GE 7FA CC 2 x LMS100w/SCR

2x1 GE 7FA CC 2 x LMS100w/SCR

NYC Long Island Lower Hudson Valley Capital District

Day

s o

f Fu

ll Lo

ad F

ue

l Bu

rn

Tank VolumeAllowance forBarge Size

InventoryAllowance forGas Constraint

InventoryAllowance forDeliveryInterruption

InventoryAllowance forDelivery Lag

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Dual-Fuel v. Firm Transportation

Levelized Annual Cost of Fuel Assurance (2018 $/kW-yr)

• Dual-fuel capability

◦ Capital Recovery

– CT supply scope (burners, I&C, etc.)

– Fuel and demin water storage / handling / receipt

– Other construction costs

– Emission reduction credits

– Net cost of startup testing on ULSD

◦ Carrying charges on ULSD Inventory

◦ Fixed O&M Costs

– Incremental labor, services and materials

– Net cost of annual testing on ULSD

– Incremental insurance and property taxes

• Net cost of FT – Monthly rate x 12 * MDQ / ICAP

Page 26: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Cost of Dual-Fuel Capability

$0

$2

$4

$6

$8

$10

$12

$14

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

2x1 GE7FA CC

2 xLMS100w/SCR

Dominion North PEPCO BGE Delmarva PECO PSEG North PSEG South

Leve

lize

d A

nn

ual

Co

st (

$/k

W-y

r)Insurance andProperty Taxes

Net Cost of AnnualTesting on ULSD

Fixed O&M Servicesand Materials

Carrying Charges onFuel Inventory

Captital Recovery onNet Cost of StartupTesting on ULSD

Capital Recovery onEmission ReductionCredits

Capital Recovery onOther ConstructionCost

Capital Recovery onFuel and Demin WaterTankage

Capital Recovery onCT Supply Scope

Note: Vertical axis scale varies for each PPA.

Page 27: Gas-Electric System Interface Study - ISO New England€¦ · Gas-Electric System Interface Study Target 4 Fuel Assurance: Dual-Fuel Capability v. Firm Transportation November 14,

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Comparison Results for Combined Cycle

$0

$20

$40

$60

$80

$100

$120

Cen

tral

CT

SW C

T

Cap

e C

od

SE M

A

Mai

ne

Ne

w H

amp

shir

e

Ver

mo

nt

NY

C

Lon

g Is

lan

d

Low

er

Hu

dso

n V

alle

y

Cap

ital

Dis

tric

t

Up

per

Pe

nn

insu

la

Twin

Cit

ies

Sou

ther

n Il

lino

is

Do

min

ion

No

rth

PEP

CO

BG

E

De

lmar

va

PEC

O

PSE

G N

ort

h

PSE

G S

ou

th

Mau

ry E

ast

Co

lber

t

Joh

nso

nvi

lle

Sum

me

r Sh

ade

Cen

tral

East

ISONE NYISO MISO PJM TVA IESO

Leve

lize

d A

nn

ual

Co

st (

$/k

W-y

r)

Dual-Fuel Capability

Firm Transportation for Natural Gas

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Comparison Results for Simple Cycle

$0

$50

$100

$150

$200

$250

$300

Cen

tral

CT

SW C

T

Cap

e C

od

SE M

A

Mai

ne

Ne

w H

amp

shir

e

Ver

mo

nt

NY

C

Lon

g Is

lan

d

Low

er

Hu

dso

n V

alle

y

Cap

ital

Dis

tric

t

Up

per

Pe

nn

insu

la

Twin

Cit

ies

Sou

ther

n Il

lino

is

Do

min

ion

No

rth

PEP

CO

BG

E

De

lmar

va

PEC

O

PSE

G N

ort

h

PSE

G S

ou

th

Mau

ry E

ast

Co

lber

t

Joh

nso

nvi

lle

Sum

me

r Sh

ade

Cen

tral

East

ISONE NYISO MISO PJM TVA IESO

Leve

lize

d A

nn

ual

Co

st (

$/k

W-y

r)

Dual-Fuel Capability

Firm Transportation for Natural Gas

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Conclusions (1)

The cost of dual-fuel capability is relatively consistent

over the range of locations

• Primary driver is inventory and storage requirements for

barge delivery

• Unit cost is higher for simple cycle due to higher heat

rates (partially offset by lower capacity factor)

Cost of fuel assurance through FT varies widely by

location

• Primary drivers are the cost of incremental FT and the

cost of local improvements

• Unit cost is higher for SC due the higher heat rate and

the lower installed capacity

Dual-fuel capability has a lower cost than net FT cost

(with few exceptions)

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Conclusions (2)

In some locations where incremental FT = embedded

costs, FT has a comparable cost to dual-fuel for CCs

Dual-fuel capability is the lower cost fuel assurance

alternative for SCs at all sites

Study limitations

• Fuel assurance from PPAs’ perspective

• Other factors affecting generators’ willingness to invest

in FT

◦ Different performance on gas v ULSD

◦ Profit margin from incremental energy sales

◦ Increased permitting difficulty to store & burn ULSD

◦ Penalty avoidance as a capacity resource

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Target 4 Production Schedule

Proposed key milestones

• Report to stakeholders: 11/07/2014

• SSC webinar re results: 11/14/2014

• Stakeholder comments due: 11/21/2014

• Final draft report to DOE: 12/05/2014