MARCH 28, 2008
FILE NO.: R-3636-2007
REQUEST FOR PARTICULARS NO. 2 OF ÉLL TO PHILIP ANSER, EXPERT
PAGE 1 OF 4
REQUEST FOR PARTICULARS NO. 2
OF ÉNERGIE LA LIÈVRE S.E.C. (« ÉLL ») TO MR. PHILIP ANSER
IN RELATION TO HIS EXPERT REPORT (HQT-7, DOCUMENT 1)
1.
Reference:
HQT-7, Document 1, expert report of Philip Anser and appendixes:
Preamble:
In relation to the report prepared by yourself and dated March 13th, 2008 filed by Hydro-Québec
TransÉnergie as HQT-7, Document 1, we would ask that you provide the following additional
information.
Demands:
1.1
Please provide a descriptive list of all of the documents including memos, notes,
contracts, spreadsheets, data, electronic data and technical information of whatsoever
nature relating to the Hydro-Québec TransÉnergie system or that of ÉLL that you were
referred to or that you were provided with for the purpose of your report as filed?
1.2
Please provide copies of all such documents.
2.
Reference: HQT-7, Document 1, pages 7, 8 and 9, “B. Hypothical load flow cases
show loop flows between ÉLL and HQ”.
Preamble:
“I have reviewed two hypothetical load flow cases provided to me by Hydro-Quebec
TransEnergie. These load flow cases are included in Appendix C. If the ÉLL system was
a radial connection to the HQ system, it would be impossible to construct a hypothetical
load flow case showing the loop flow between the ÉLL system and the HQ system. As I
will illustrate in the next paragraphs, power flow can be looped from the MATI
interconnection point to MAFA interconnection point. The following load flow scenarios
purposely assume zero output at some of ÉLL’s generating units to show the possibility
of loop flows originating from the MATI interconnection.
Diagram 2 in Appendix C provides a depiction of a load flow scenario involving the ÉLL
and HQ systems when ÉLL is synchronized to the HQ system. ÉLL’s MAHO
interconnection to Hydro One is assumed to be open (i.e., the ÉLL system is not
synchronized to Hydro One). In this load flow diagram, both the interconnections at MATI
and MAFA were closed in order to observe how power could be looped through the ÉLL
system, entering from MATI and exiting through MAFA. For the purpose of this exercise,
line 1125 was tripped and production was fixed at 0 MW for the High Falls and the
Rapides-des-Cedres generating stations. The results obtained are consistent with my
previous conclusions -- the load flow diagram shows a northward flow of power towards
MAFA (the Notre-Dame-de-Laus substation load) on the HF1, HF2, and 1123 lines.
MARCH 28, 2008
FILE NO.: R-3636-2007
REQUEST FOR PARTICULARS NO. 2 OF ÉLL TO PHILIP ANSER, EXPERT
PAGE 2 OF 4
Diagram 3 in Appendix C is another load flow case involving the ÉLL and HQ systems
under synchronization. This diagram represents a situation where all of ÉLL’s generating
units and the White Birch mill load are out of service.”
Demands:
2.1
Please provide copies of all documents that prior to the filing of your report you
consulted in relation to the scenarios referred to at pages 7, 8 and 9 of your report
(Diagrams 1, 2 and 3 of appendix C to your report) including, without being restrictive,
any load flow data, single line diagrams, load requirements, transmission capacity, etc.
2.2
At page 7 of your report, you refer to the fact that you reviewed for the purpose of said
report two hypothetical load flow cases provided to you by Hydro-Québec TransÉnergie.
Please provide, if any, all information data, spreadsheets and reports provided by HydroQuébec TransÉnergie in relation to said load flow cases that were not filed with your
March 13th, 2008 report?
2.3
Please provide any copies of any other hypothetical load flow cases or scenarios which
were provided to you by Hydro-Québec TransÉnergie along with all supporting
documentation.
2.4
Did you complete or require the completion of any other load flow analyses or
simulations?
2.5
If affirmative, please provide a list of such load flow analyses and simulations along with
all the information, documentation and technical data, charts, diagrams that when
collected, provided or produced in relation to such additional load flow cases and
analyses.
3.
Reference:
HQT-7, Document 1, page 9:
Preamble:
At page 9, 3rd paragraph of your report, you refer to Common Operating Instructions between
ÉLL and Hydro-Québec TransÉnergie.
Demands:
3.1
With regards to the constraints associated with Common Operating Instructions, what
analysis, if any, did you make of the technical and operational reasons justifying the
prohibitions and constraints imposed by the Common Operating Instructions on the use
and operations of the interconnections?
3.2
In the affirmative, please provide copy of such analysis and any supporting
documentation produced by you prior to your report.
MARCH 28, 2008
FILE NO.: R-3636-2007
REQUEST FOR PARTICULARS NO. 2 OF ÉLL TO PHILIP ANSER, EXPERT
PAGE 3 OF 4
4.
Reference:
HQT-7, Document 1, page 10 :
Preamble:
At page 10 of your report “B. Historical Data shows actual loop flows between the ÉLL system
and the Hydro One Network”, you refer to energy being looped from D5A to H9A.
Demand:
4.1
At page 10 of your report, you refer to energy being looped through D5A to H9A to the
Ontario system. What analysis was made by you, prior to your report, concerning the
context and conditions underlying an operation of said interconnection ties, which under
normal operating conditions would be strictly prohibited under the Hydro One and IESO
joint operating instructions?
5.
Reference:
HQT-7, Document 1, figure 3, page 12 and HQT-6, Document 1:
Preamble:
At page12 of your report, you refer to figure 3 which is also filed as HQT-6, Document 1, by
Hydro-Québec TransÉnergie.
Demands:
5.1
Concerning the scenario outlined at page 12 of your report and referred to by HydroQuébec as HQT-6, Document 1, figure 3, why would it be necessary under this scenario
that the MAHO interconnection be at 0 MW and what impact on the ÉLL system does
this imply?
5.2
Your statement contained at page 12 of your report concerning figure 3, HQT-6,
Document 1, is that such a scenario would allow for firm transmission service to the
White Birch Mill without requiring any changes or modifications to ÉLL’s system. Would
such transmission service, under this scenario, still be possible if all of ÉLL’s generating
stations were offline?
5.3
Were you asked to determine, prior to your report, what would be the required
contribution of ÉLL’s generating capacity in order to allow for firm transmission service
that would meet Hydro-Québec TransÉnergie’s norms and reliable operating criteria and
in the affirmative please provide your conclusions?
5.4
Would such transmission service scenario (Figure 3) still be possible if all of ÉLL’s
generating capacity was synchronized with the Ontario system?
5.5
Had you ascertained for the purpose of your report of March 13, 2008, any other
scenarios that would entail a capacity to provide firm transmission service without
changes or modifications or additions to the ÉLL system and which meet the HydroQuébec TransÉnergie norms and operating criteria?
MARCH 28, 2008
FILE NO.: R-3636-2007
REQUEST FOR PARTICULARS NO. 2 OF ÉLL TO PHILIP ANSER, EXPERT
PAGE 4 OF 4
5.6
In the affirmative, please provide a description of such scenarios and supporting
documentation.
6.
Reference:
HQT-7, Document 1, page 4:
Preamble:
“It is worth noting that a facility with a non-radial connection can choose to operate itself
in a manner that creates a radial interconnection because of operational constraints or
economic motivations, but that does not change the inherent nature of the facility’s
connection.”
Demand:
6.1
At page 4 of your report, you refer to the concept of choice of the system operator in
acting in a manner that creates a radial interconnection rather than a non-radial
connection. Are you suggesting that safety and reliability considerations established by
joint operating instructions and reliability requirements which prohibit looping or nonradial operation of an interconnection tie, should not be taken into account in
determining whether or not a system is capable of providing non-radial access?