GenOn Energy, Inc. _ Bowline 3 and Lovett ... - Energy Highway

Response to
new yoRK eneRGy hIGhway
Request foR InfoRmatIon
BY GENON ENERGY, INC.
MAY 30, 2012
WWW.GENONBOWLINE.COM

Contents
Introduction
Required Information
Respondent Information
Project Description – Bowline 3 Generation Project
Project Justification
Financial
Permit/Approval Process
Other Considerations if Applicable
Additional Information
Property
Projected In-Service Date and Project Schedule
Interconnection
Technical
Construction
Operational
Socio-Economic
Financial
Environmental
Project Contract / Request for Proposal (RFP) Status
Public Outreach and Stakeholder Engagement
Appendix
Appendix A: Bowline site--current aerial overview photo
Appendix B: Bowline 3 Construction Site – Current Aerial Photo
Appendix C: Conceptual Layout of Bowline 3
Appendix D: Conceptual Bowline 3 – Facility Profile
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Introduction
GenOn Energy, Inc. (“GenOn”) through one of its indirect subsidiaries is pleased to
participate in the State of new York’s Energy Highway Request for Information (“RFI”).
GenOn intends to offer attractive solutions to new York’s energy challenges. Our proposal
focuses on developing a clean generating power project at our existing GenOn Bowline
Station, a brownfield site in Haverstraw, new York. In addition to our proposal for the
Bowline site, we are eager to work with new York to also develop a project at our GenOn
Lovett location, a developable brownfield site in Stony Point, new York.
Each of these sites is located near existing interconnection infrastructure and is ideal for
serving the energy needs of the downstate and Lower Hudson Valley regions. Both Bowline
and Lovett present unique opportunities to deliver safe, affordable, and reliable energy
for new York State. we are willing to tailor our projects to meet the needs of the State and
look forward to engaging in a partnership that will serve the interests of the State with our
projects.
Required Information
Respondent InfoRmatIon
GenOn Energy, Inc. (nYSE: GEn) is one of the largest competitive generators of wholesale
electricity in the United States, with power generation facilities located in key regions of
the country and a generation portfolio of approximately 23,700 megawatts. GenOn has
approximately 3,400 employees and is headquartered in Houston, Texas.
GenOn’s portfolio of power generation facilities consists of 47 stations in 12 U.S. states
and includes baseload, intermediate and peaking units using coal, natural gas and oil to
generate electricity. The company has owned and operated electric generation facilities
in the state of new York since 1999. Currently, GenOn owns and operates the Bowline
generation facility in Haverstraw, new York, which consists of two natural gas/oil units
with a combined nominal capacity of 1,139 mw and owns the Lovett site located in
Stony Point, new York.
maintaining a strong organizational focus on safety and the environment is a core value
at GenOn. The company is committed to a fleetwide "Zero Incident Culture” and strives
to ensure that appropriate resources and training are provided at all levels of the enterprise
in order to consistently achieve industry-leading safety performance. GenOn
uses a comprehensive environmental management system, integrating environmental
considerations into business operations and strategy. The company fosters a culture
of continuous improvement, always driving for better, more effective, more efficient
environmental performance.
GenOn possesses significant experience and capabilities in the development of new power
generation stations. Since the late 1990s, GenOn has successfully developed over 12,000
megawatts of natural gas-fired simple cycle and combined cycle power generation facilities
throughout the United States. GenOn’s development capabilities are comprehensive and
include permitting, engineering, procurement and construction (EPC) management,
project financing, and plant operations. The company also has extensive experience with
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a wide range of power generation technologies (e.g., GE, Siemens, mitsubishi, and Alstom)
and both wet and dry cooling equipment. GenOn has successfully developed power
plants on greenfield sites as well as redeveloped existing brownfield sites to host new
generation assets.
A recent example of GenOn’s brownfield development experience is the marsh Landing
Generating Station located just outside of San Francisco, California. This 760 megawatt
peaking facility is being built near GenOn’s existing Contra Costa generating units, which
are scheduled for retirement in 2013. This brownfield development project was specifically
designed to maximize the use of existing site infrastructure such as natural gas pipelines
and electric transmission lines, enabling the state of California to preserve greenfield sites
for other development needs or as open space.
marsh Landing's output is fully contracted to California utility Pacific Gas and Electric
Company (PG&E) under a long-term tolling agreement. The project benefited from a very
efficient development and permitting schedule, with less than 2 1/2 years from the initial
permit application to the start of construction. This highly successful project included full
permitting as well as contracting for procurement of power island equipment and fullwrap,
fixed-price EPC services. The estimated cost of the marsh Landing project is approximately
$700 million. Funding for the project consisted of a combination of GenOn equity
and a bank debt facility arranged by GenOn.
Questions or requests for additional information regarding this Energy Highway RFI
response document may be addressed to:
mr. Gary Kubik
Vice President northeast
GenOn Energy, Inc.
President
GenOn Bowline, LLC
140 Samsondale Avenue
west Haverstraw, new York 10993
(832) 357-6977
gary.kubik@genon.com
pRoject descRIptIon – BowlIne 3 GeneRatIon pRoject
GenOn is pleased to submit for consideration as part of new York’s Energy Highway initiative
our proposal for "Clean Gen on the Hudson" – – the Bowline 3 generation project.
Upon the finalization of commercial arrangements with the State, and the construction
that would follow, Bowline 3 will be a highly efficient, clean, 2 x 1 combined cycle gas
turbine (CCGT) electric generating station in the town of Haverstraw, new York (Rockland
County, nYISO Zone G). The capacity of this new facility will be approximately 775 mw
(ISO). Bowline 3 is a brownfield development project that will be built adjacent to
existing Bowline Units 1 and 2 on approximately 25 acres of previously-cleared land.
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The Bowline 3 CCGT will use efficient combustion turbine technology and will have state-
of-the-art emissions control equipment. The primary fuel for Bowline 3 will be natural gas.
If desired, Bowline 3 could utilize ultra-low sulfur #2 diesel fuel as a backup fuel source.
natural gas will be delivered to Bowline 3 via an existing 4.2 miles of 24-inch diameter
natural gas pipeline lateral, which connects directly to the millennium pipeline. The pipeline
lateral is capable of delivering 12,000 mmBtus of natural gas per hour to Bowline,
which is more than sufficient to support operation of the planned new unit.
Bowline 3 will use a state-of-the-art Air Cooled Condenser (ACC) unit to handle the
cooling portion of its steam cycle. Air cooling will reduce overall plant water requirements
by approximately 95% when compared to traditional wet cooling. Bowline 3 will not require
intake structures on, nor require water from, the Hudson River. Consumptive water used
by Bowline 3 will be obtained via available local supplies.
Safe and affordable electricity generated by the Bowline 3 facility will be delivered to the
grid via a 345 kV transmission line. This new line, approximately 7 miles in length, will commence
at the existing Bowline switchyard and will be constructed on land or easements
owned by GenOn as well as utility rights-of-way owned by Orange & Rockland (O&R). The
line will connect to the bulk electric grid at O&R’s Ladentown substation located in the
town of Ramapo, nY.
A key attribute of Bowline 3 is its emphasis on brownfield development. The project will
repower the current Bowline facility through the extensive reuse of existing and unutilized
assets, including:
• A previously-cleared, shovel-ready site immediately adjacent to the existing
• Bowline generation units;
• A 24-inch natural gas pipeline lateral;
• A river terminal facility for delivery of ultra-low sulfur diesel #2 fuel oil to the facility via
marine barge (if a dual fuel option is desired);
• A fuel oil storage tank for on-site storage of up to 140,000 barrels of ultra-low sulfur
diesel #2 fuel oil (if a dual fuel option is desired);
• Land and easements owned by GenOn as well as existing utility rights-of-way for
transmission interconnection;
• NOx and VOC emissions reduction credits (ERCs) in GenOn’s current inventory to
support the operation of the new Bowline 3 facility plus a pending application for Pm
2.5 ERCs to complete the portfolio of ERCs required for the issuance of an air permit
for the Bowline 3 project.
The actual project schedule and estimated in-service date for Bowline 3 will be driven
by the Governor's Energy Highway process. GenOn is confident that Bowline 3 can be
online within 3 ½ years of receipt of final regulatory and contractual approvals. GenOn
recognizes an opportunity for public-private collaboration to secure the future of
this project.
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GenOn will procure state-of-the-art combustion turbines, heat recovery steam generators,
steam turbine, air cooled condenser, and balance-of-plant equipment for the construction
of Bowline 3. These technologies are widely available in the marketplace and have strong,
well-documented performance track records. GenOn will seek to utilize qualified providers
of equipment, materials and services located in the new York State region where possible
and practical.
pRoject justIfIcatIon
Bowline 3 addresses key objectives and goals of the new York Energy Highway initiative as
enumerated in the RFI.
1. OBJECTIVE: Reduce constraints on the flow of electricity to, and within, the downstate
area; and expand the diversity of power generation sources supplying downstate.
Assure that long-term reliability of the electric system is maintained in the face of
major system uncertainties.
Downstate new York, and the Lower Hudson Valley in particular, faces the possibility
of significant near-term retirements of generating capacity due to weak market con-
ditions and pending environmental regulations. These retirements threaten to jeopardize
electric grid reliability in this critically important region of new York's bulk electrical
system. Bowline 3, as an efficient CCGT facility capable of operating at a high
capacity factor, will provide the replacement voltage support and power necessary to
deliver safe and affordable grid reliability in the Lower Hudson Valley region. maintaining
voltage levels in the Lower Hudson Valley is critical to optimizing new York’s ability
to transfer energy efficiently to, and within, the downstate region, which is the largest
driver of the statewide economy.
2. OBJECTIVE: Encourage development of utility-scale renewable generation resources
throughout the State.
As new York adds more renewable generation, the intermittent nature of these power
resources will create challenges for system operators seeking to maintain a constant
balance between load and generation. In this instance, the burden of maintaining
system reliability will fall increasingly on the flexible operation of well-located thermal
generation units. Bowline 3, as a state-of-the-art CCGT unit, will provide operational
flexibility and load-following capability that will contribute to safe and affordable grid
reliability and facilitate the transfer of renewable energy to the downstate region. This
capability will be especially critical if high capacity factor, baseload generation units
currently serving the downstate region are removed from the generation mix.
3. OBJECTIVE: Increase efficiency of power generation, especially in densely populated
urban areas.
As a CCGT unit with an ISO heat rate of approximately 6,800 mmBtu/kwh and designed
to burn low-cost natural gas, Bowline 3 will be much more efficient and environmentally
friendly than the older, less efficient gas/oil boiler units, which constitute
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a large proportion of the downstate generation fleet. Bowline 3’s streamlined permitting
status and high capacity factor operation will allow for the displacement or later
re-powering of older, less efficient units, including those located in densely populated
urban areas, and result in lower overall emission levels in new York. moreover, as a
brownfield development project, Bowline 3 will be an efficient and cost-effective alternative
to the development of new sites and requisite interconnections in congested
urban and suburban areas as well as to the long-distance delivery of energy over
already-congested transmission lines.
4. OBJECTIVE: Create jobs and opportunities for new Yorkers.
Bowline 3 is expected to create 700 skilled construction jobs and approximately 25
high-quality, permanent jobs for personnel to operate the plant once it is completed.
The project will also support hundreds of local jobs among vendors and suppliers.
In addition, Bowline 3 will play an integral role in securing safe and affordable grid
reliability for the region, spurring additional job creation and economic development.
5. OBJECTIVE: Contribute to an environmentally sustainable future for new York State.
Bowline 3 will be outfitted with state-of-the-art technology designed to protect
environmental quality for Haverstraw, the region and the Hudson River. The integration
of air cooling technology will eliminate any environmental impact on the Hudson River
and reduce overall plant water requirements by approximately 95% when compared
to traditional wet cooling. In addition, highly-efficient, clean, state-of-the-art combustion
turbine generation technology will be minimally impactful on local air quality.
Brownfield development projects such as Bowline 3, by definition, minimize impacts
on the environment and the surrounding community.
fInancIal
GenOn intends to fund Bowline 3 with a combination of equity and long-term project
financing debt. Given this, the commercial arrangements must allow for the project to be
financeable. To construct Bowline 3, GenOn will procure state-of-the-art technologies and
EPC services from leading manufacturers and providers. Equipment and services of this
type are long lead time items and must be ordered well in advance of breaking ground.
Having developed and constructed over 12,000 mw of gas-fired power plants in the United
States, GenOn is very experienced in managing the price and schedule risks typically
associated with complex infrastructure construction projects.
peRmIt/appRoval pRocess
GenOn has made significant progress in its permitting effort for Bowline 3 and is actively
carrying forward efforts to reflect design enhancements that will improve the environmental
qualities of the project. These enhancements include improved turbine technology
and converting from wet cooling to dry cooling. Because Bowline 3 has progressed favorably
with the State and because the proposed changes benefit the environment, GenOn
believes Bowline 3 will not face material permitting uncertainties and can quickly satisfy
State permitting requirements.
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Substantive local permitting provisions will be addressed with the Article X Certificate.
Finally, GenOn will pursue required federal permits, if any.
otheR consIdeRatIons If applIcaBle
nYISO Transmission Queue: GenOn has recently submitted to new York Independent
System Operator (nYISO) an application to connect Bowline 3 to the new York transmission
grid. we are concerned that the many uncertainties currently facing new York's electrical
system (e.g., pending generator retirements and proposed upgrades to the nYISO
transmission system) may complicate nYISO’s ability to evaluate the impact of interconnecting
new generation projects. GenOn is requesting close and careful coordination
between Governor Cuomo's Energy Highway Task Force and nYISO in order to ensure
that the potential transmission system impacts of high-potential projects currently in
the transmission queue are able to be evaluated in a timely fashion.
new Generation at Lovett Site: The information in this RFI response addresses the potential
for new generation at GenOn’s existing Bowline site. In addition, GenOn is evaluating several
options for the addition of new generation at the GenOn Lovett site. The Lovett site is
on the Hudson River in Stony Point, new York approximately 5 miles north of Bowline. Formerly
the site of coal and natural gas generation units, Lovett is now a completely cleared
brownfield site consisting of approximately 58 developable acres. The site is located on the
high demand side of major new York transmission constraints and is close to major natural
gas pipelines and electric transmission lines. Overall, Lovett is a highly attractive location
for the construction of new generating units, and GenOn is evaluating which of several new
generation configurations (e.g., combined cycle or peaking units) it will seek to permit at
Lovett. GenOn welcomes the opportunity to discuss with new York officials the type of new
generation at Lovett that will best fit the needs of the Energy Highway initiative.
Recommended Evaluation Criteria: In order to provide maximum benefit to new York
energy consumers, we recommend that the State of new York, when evaluating projects
for inclusion in the Energy Highway initiative, give priority consideration to projects that
demonstrate the following characteristics:
1. Emphasis on brownfield development – Projects that use existing power generation
sites, gas and electric transmission infrastructure and rights-of-way, emissions
credits, and fuel supply and storage infrastructure will enable the state of new York
to achieve the goals of the Energy Highway initiative in a manner that is cost-effective,
low risk, and minimally impactful on local communities and the environment.
2. High executability – The new York Energy Highway initiative seeks to identify projects
that can provide reliable power to the state's consumers for the next half-century. As
such, new York should prioritize projects that:
a. Rely on proven, widely available technologies;
b. Are backed by financially-sound and committed sponsors with a proven track
record of permitting, constructing, financing, owning, and operating similar
projects; and
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c. Provide certainty of execution that result from the presence of existing site
infrastructure, the availability of gas and electric interconnections, and a
beneficial location within the transmission system.
3.
Capable developers, operators and owners – A key goal of the Energy Highway initiative
is to maximize the role of private investment in developing new energy infrastructure
in new York. In general, new York should seek to partner with private companies
that possess strong balance sheets, have excellent reputations within the banking
community, and are willing to and capable of making financial commitments to the
projects that they propose for inclusion in the Energy Highway initiative.
Additional Information
pRopeRty
The site on which Bowline 3 will be constructed is part of the existing Bowline generation
facility and is owned by a wholly-owned, indirect subsidiary of GenOn Energy, Inc.
In general, the Bowline 3 site is ideally suited for large-scale construction and efficient
operations that minimize the facility’s impact on neighboring communities given the
following site characteristics:
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The Bowline 3 site has already been cleared, which will allow for the immediate
commencement of foundation and other construction-related work;
marine barges carrying heavy equipment have easy access to the site given
Bowline 3’s direct frontage on the Hudson River;
The plant’s existing bulkhead dock on Bowline Pond (which opens directly to the
Hudson River) allows for safe, efficient unloading of heavy equipment delivered to the
site via marine barge;
Bowline 3 is located within 1 mile of csX rail siding, which provides an additional
means of delivering other equipment to the site;
Fuel is supplied to the site by an existing, fully permitted, 24 inch natural gas pipeline
on property either owned by GenOn or part of existing utility rights of ways or easements
granted to GenOn; and
Power from the site can be delivered to the electrical grid via a 345 kV transmission
interconnect to be constructed on property either owned by GenOn or part of
existing utility rights of ways or easements granted to GenOn.
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pRojected In-seRvIce date and pRoject schedule
The actual project schedule and estimated in-service date for Bowline 3 will be driven by
the time frame of the Energy Highway process and achieving all regulatory and contractual
approvals. The indicative schedule below is based on GenOn’s recent development experience
with new generating units of similar size and technology as Bowline 3. The schedule
demonstrates that all required steps to reaching commercial operation of Bowline 3,
including project financing, will be achieved within 3 1/2 years of final regulatory and
contractual approvals.
BowlIne 3–IndIcatIve schedule
Regulatory/contractual approvals
financing
finalize engineering & order equipment
construction
testing and commissioning
commercial operations
InteRconnectIon
Connecting the highly efficient Bowline 3 to the electrical grid at a location that is on the
high-demand, high-price side of major new York transmission system constraints (e.g.,
the East-west and UPnY-SEnY interfaces) will provide economic benefits to new York
consumers and will mitigate reliability impacts that may result from generator retirements
in downstate new York in general and in the Lower Hudson Valley in particular. GenOn also
believes that connecting to the grid downstream of major points of constraint will minimize
overall system upgrade costs required to make Bowline 3’s energy and capacity deliverable
to the bulk electric system.
technIcal
As is customary for high-value projects of this nature, GenOn will seek comprehensive warranties
for two years or more on all equipment, materials, and workmanship utilized during
the construction process. The anticipated design life of CCGT facilities such as Bowline 3 is
at least 30 years.
constRuctIon
GenOn development projects typically provide attractive opportunities for local manufacturers,
assemblers, construction firms, and workers. GenOn will seek to utilize qualified
providers of equipment, materials, and services located in the new York State region where
possible and practical.
To facilitate the financing of a project such as Bowline 3, GenOn typically seeks to execute
a full-wrap, fixed-price, date-certain, turnkey EPC contract with an experienced, nationally
recognized firm. This type of contract benefits project owners and lenders because it
provides an attractive combination of cost efficiency, schedule certainty, and performance
guarantees.
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Having owned and operated electric generation facilities in new York since 1999, GenOn is
very familiar with issues related to the local availability of labor, materials, and installation
equipment. In general, we anticipate that the Bowline 3 project will be built utilizing a skilled
unionized workforce in a manner similar to other construction projects that GenOn is
currently executing in other parts of the country. Depending on market conditions at
the time construction commences, we believe that skilled, unionized labor will be available
in sufficient quantities, either locally or from neighboring regions, to execute the project
in a cost-effective and timely manner. GenOn historically has enjoyed good relations with
building and construction trades groups. The ongoing construction of the company’s
marsh Landing plant in California, for example, has benefited substantially from the highlyproductive,
quality-focused efforts of numerous building and construction trades groups
working on the project.
opeRatIonal
GenOn has significant experience with the ownership and operation of power generation
facilities that contain explicit guarantees related to project availability and performance.
Although GenOn is not yet aware of the exact structure that new York will offer in support
of Energy Highway projects, it is our expectation that such structures will require Bowline 3
to operate at a high level of availability and performance.
GenOn has a strong, company-wide commitment to safety. we promote a safe and healthful
work environment, communicate safety issues, use safe work practices and provide
ongoing safety training for our employees. For both construction projects and plant operations,
GenOn maintains a comprehensive safety program and manual that together set a
high standard for safety. In addition, we require that all our contractors commit to a set of
safety procedures that are at least as rigorous and comprehensive as our own.
Bowline 3 will also maintain a comprehensive plan for addressing emergency situations. In
addition, we expect to contract with local entities to provide emergency response services
to the plant.
socIo-economIc
The construction and operation of major infrastructure projects such as Bowline 3 typically
provide a variety of economic benefits to the communities in which they are located.
These benefits typically include the provision of well-paying jobs, tax revenue, and other
forms of associated community benefits and economic development.
Although construction plans remain to be finalized, projects of similar size and type as
Bowline 3 are capable of creating up to 700 skilled construction jobs during the plant
construction period and up to 25 high-quality, permanent jobs for personnel to operate the
plant once it is completed. In addition, Bowline 3 will support hundreds of other local jobs
among vendors and suppliers.
As is typical for projects of this type, GenOn will seek to negotiate a PILOT (Payment in Lieu
of Taxes) agreement that will represent a long-term source of revenue for the town government
and the local school district. Besides assisting the local community by maintaining a
stable tax base, a PILOT agreement is required to stabilize the project’s long-term operating
costs, which in turn is a prerequisite for GenOn to arrange a debt financing package for
the project.
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As part of the Bowline 3 project, GenOn will seek to continue its past track record of being
an active and engaged community partner. Bowline Generation Station employees currently
volunteer time and provide financial support to several community causes in Rockland
County. These meaningful contributions will continue to benefit local organizations
whose work advances and/or promotes health, welfare, education, economic development,
or other important public interests within the local community.
As a brownfield development project, Bowline 3 will minimize impacts in areas typically of
concern to the local community, particularly when compared to projects utilizing greenfield
sites. while we continue to investigate the impact of the proposed project, at this time
GenOn does not believe that adding a third generation unit to the existing Bowline facility
will have negative implications; rather, the facility will be a boon to the economic development
of the area and the facility will contribute to revitalization and continued improvements
in the community - the goals of a smart growth policy.
fInancIal
Please see the response provided under the financial heading in the "Required
Information"section of this document.
envIRonmental
Brownfield development projects such as Bowline 3, by definition, minimize impacts on the
environment and the surrounding community.
From an air emissions standpoint, the highly-efficient, clean, state-of-the-art combustion
turbine generation technology that will be utilized by Bowline 3 will provide important
environmental benefits to the surrounding region and the state of new York. Given Bowline
3’s high efficiency, GenOn anticipates that the plant will be dispatched ahead of older, less
efficient, less clean generation units in the downstate region. This displacement of higher
emissions units will constitute a net benefit to the region’s air quality. Bowline 3's CO2 performance
will also exceed that of units it will displace.
Bowline 3 will also benefit new York’s water resources. For example, we anticipate that
Bowline 3 will displace the operation of once-through-cooled units in downstate new York.
Adding to Bowline 3’s beneficial impact on water resources is the fact that the unit’s use of
dry cooling will not require cooling water discharges and therefore will not produce aquatic
ecology impacts to the Hudson River from such discharges.
when the Bowline 3 site was cleared and prepared for construction, a small federal
wetland (which was identified as part of the U.S. Army Corps of Engineers approval) was
relocated. Beyond this, GenOn expects that any additional ecological impacts will be minimal
given that the site is essentially “shovel-ready.” GenOn does not anticipate that
the project will require any significant additional mitigation measures.
pRoject contRact / Request foR pRoposal (Rfp) status
The Bowline 3 project has not been submitted to any new York State agency or authority in
response to a request for proposals (RFP).
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puBlIc outReach and staKeholdeR enGaGement
GenOn seeks to be an active and engaged partner in all of the communities across the
United States where we own and operate generation assets or seek to execute development
projects. As an essential component of the Bowline 3 project, GenOn will seek to
identify key stakeholder groups and affected individuals. The company will also seek to develop
a comprehensive public outreach and information program designed to ensure that
stakeholders understand the important benefits that the project will provide to the state of
new York and to the surrounding community. This program will provide ample opportunities
for members of the public to ask questions and discuss concerns that they may have
about the project.
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Appendix
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appendix a: Bowline site--current aerial overview photo
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appendix B: Bowline 3 Construction Site – Current Aerial Photo
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appendix c: Conceptual Layout of Bowline 3
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appendix d: Conceptual Bowline 3 – Facility Profile
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