Download Gas Curtailment Plan - Maryland Public Service Commission

Baltimore Gas and Electric Company
Natural Gas Curtailment Plan
I.
Application of the Curtailment Plan
A.
Section 2.3 of the Gas Service Tariff specifies that in the event a curtailment of gas
service is required, the Company will implement limitations to service in accordance with
this Natural Gas Curtailment Plan which has been approved by the Public Service
Commission of Maryland. This Plan establishes and documents procedures that BGE
follows to assure natural gas service reliability to Maryland’s firm service natural gas
customers. Emphasis is placed on maintaining service to high priority, essential human
needs. The Plan documents the hierarchy of gas service and use during extraordinary
situations and is consistent with Public Service Commission regulations, Maryland
Emergency Management Agency (MEMA) requirements, BGE’s Gas Emergency
Manual Standards and the Maryland Natural Gas Supply Contingency Plan.
B.
It is the Company’s policy to plan for a variety of demand and market conditions. These
plans include strategies and practices to mitigate service interruptions and increase
reliability of service. However, in the event that the Company is unable at any time to
maintain safe minimum delivery pressure on part or all of its distribution system on a
daily or seasonal basis, this Curtailment Plan will be implemented.
C.
The curtailment of firm service loads detailed in this Curtailment Plan does not reflect a
rigid sequence of operations, but rather a flexible option of alternatives necessary to
react quickly and effectively to various circumstances. Timing is of critical importance
since protection of the distribution system reliability is paramount, and the curtailment of
firm service loads is time consuming and costly to the Company and threatening to
customers. The steps detailed in this Plan may be implemented either sequentially or
simultaneously depending on the nature and extent of the emergency.
D.
This Plan will be followed in the event of a major disruption in gas supply, interstate gas
pipeline transportation capacity or distribution system capacity including, but not limited
to:
1.
Facility failure on an interstate gas pipeline system impacting the pipeline’s ability
to deliver gas to the Company’s City Gate;
2.
Facility failure on the Company’s distribution system;
3.
Short term loss of gas commodity supply;
4.
Interstate gas pipeline curtailment of contract services;
5.
Shortage of BGE storage inventory or peak shaving feedstock; or
6.
Extreme temperature conditions that exceed prudent design day and seasonal
supply design criteria.
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Baltimore Gas and Electric Company
Natural Gas Curtailment Plan
E.
This Plan consists of three levels of actions that will be undertaken by the Company:
1.
Prior to implementing the curtailment of firm service loads, concurrent efforts will
be taken to:
a.
Reduce the Company’s and customers’ demand, and
b.
Increase gas supply and/or interstate gas pipeline transportation
capacity.
2.
Curtailment of individual customers’ loads where sufficient time permits actions
to be taken, and
3.
Total curtailment within specific areas where immediate action is necessary to
maintain service to the largest number of customers while impacting as few
customers as possible.
F.
Critical Use (Dth) – Critical use is that amount of gas required for pilot use or to protect
life, health and public safety. In the application of this definition, the gas outage would
be for a period of time up to 24 hours. Critical Use also includes that amount of gas
where an outage for up to 24 hours would cause irreparable damage to the environment
and / or the Customer’s property. The total amount of Critical Use gas under Schedule
IS is limited to 10 percent of the annual average daily load of Schedule IS. Marketing &
Energy Services will develop and maintain a listing of those customers with Critical Use
and the amount of gas in Dth identified as Critical. This listing is reviewed and updated
in September of each year and is reported to Gas Planning & Engineering and Gas
Operations.
G.
Large General Service customers served under Schedule C are grouped into
categories:
H.
two
1.
Business Significant Customers – Business Significant customers are the 30
largest Schedule C (classification CL) customers which have not elected NonStandby Service. Marketing & Energy Services will develop and maintain a
listing of customers in this category. Critical Use for these customers will be
individually determined.
2
Sensitive Customers – Sensitive customers are those large Schedule C
(classification CL) customers which are not defined as Business Significant nor
have elected Non-Standby Service. Marketing & Energy Services will develop
and maintain a listing of customers in this category. Critical Use requirements
for customers in this category are either zero (0) or 100 percent of their load.
The Curtailment Penalty Rate is $100 per Dth.
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Baltimore Gas and Electric Company
Natural Gas Curtailment Plan
I.
Sudden Failure of Alternate Fuel Systems: Customers who experience a sudden
failure of their alternate fuel system, upon obtaining permission and if conditions permit,
will be allowed sufficient gas to permit an orderly shut-down or a quick repair. If
permission is granted, gas used will be treated as Critical Use gas for up to 6 hours.
When permission is denied, gas used will be charged to the Customer at the
Curtailment Penalty Rate.
J.
Where a curtailment of natural gas service is required under this Plan, a report will be
submitted to the Commission within 30 days following the restoration of service
explaining the causes of the curtailment. In the event that the curtailment extends
beyond 3 months, interim reports will be submitted on a quarterly basis.
Activities Prior to Implementing Curtailment – If a situation threatens to
jeopardize the reliability of natural gas service to the Company’s customers, prior to
implementing the curtailment of customers’ loads, the Company will concurrently undertake the
following actions:
II.
A.
B.
Efforts to reduce customers’ demand:
1.
Facilities & Fleet Services will reduce the use of gas in Company facilities.
2.
Appeals for conservation will be issued by Corporate Communications to the
mass market using pre-approved messages where appropriate.
3.
Marketing & Energy Services will notify Schedules IS and AIS customers that
their use is interrupted under the provisions of the rate schedules.
4.
Marketing & Energy Services will solicit voluntary gas load reductions from the
largest customers. These customers are pre-identified as the largest 50
customers served under Schedule C, the Bethlehem Steel Corporation and
Electric Generation. Marketing & Energy Services will develop and maintain a
listing of customers in this category.
Efforts to increase gas supply:
1.
Interstate gas pipeline firm transportation capacity that BGE has contracted for
and has released, with recallable rights, to the secondary market under the
Federal Energy Regulatory Commission (FERC), or has used under the
Company’s Off-System Sales Program will be recalled in accordance with the
Capacity Release agreements by Gas Supply & Bulk Sales. Any gas commodity
associated with the recalled Off-System Sales transportation capacity will be
included in the recall and used for system supply purposes.
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Baltimore Gas and Electric Company
Natural Gas Curtailment Plan
2.
Gas Supply & Bulk Sales will use all resources available to obtain additional gas
commodity supplies and/or interstate pipeline transportation capacity. These
resources include, but are not limited to:
a.
Requests for excess interstate pipeline transportation and/or storage
rights;
b.
Additional City Gate gas commodity purchases;
c.
Appeals to other local distribution companies for assistance;
d.
Appeals to gas marketers and other holders of firm interstate pipeline
capacity for gas commodity and/or additional capacity;
e.
The use of non-historic resources, such as alternative interstate pipeline
routes; and
f.
Additional Liquified Natural Gas (LNG) and propane transported to the
Companies vaporization facilities by truck.
Curtailment Hierarchy – If the activities described above are insufficient and it
becomes necessary to curtail service, and there is sufficient time to implement the procedures
described below, customers’ use will be curtailed under the guidelines listed below.
Compensation for any transportation gas arriving at the Company’s City Gate for a customer
which has been curtailed is made under the terms of Section V.
III.
A.
Marketing & Energy Services will notify Schedules IS and AIS customers that their use
is curtailed to Critical Use levels. Critical Use gas will be billed as Permission Gas.
These customers will also be notified that Production Gas above Critical Use levels will
not be available. Any gas used in excess of Critical Use levels will be charged to the
Customer at the Curtailment Penalty Rate.
B.
Marketing & Energy Services will notify the Bethlehem Steel Corporation that their use is
curtailed to Critical Use levels. Critical Use gas in excess of Transportation Gas arriving
at the City Gate will be billed at the Production Rate. The Customer will also be notified
that Production Gas above Critical Use levels will not be available. Any gas used in
excess of Critical Use levels will be charged to the Customer at the Curtailment Penalty
Rate.
C.
When the cause for the curtailment is supply related, Marketing & Energy Service will
notify Schedule C Non-Standby Service customers that their use of BGE Gas
Commodity Service is curtailed to Critical Use levels. Critical Use gas in excess of
Transportation Gas arriving at the City Gate will be billed at the Production Rate. These
customers will also be notified that Production Gas above Critical Use levels will not be
available. Any gas used in excess of the larger of verified Transportation Gas arriving at
the City Gate or Critical Use levels will be charged to the Customer at the Curtailment
Penalty Rate. Under all other situations, Schedule C Non-Standby Service customers
are included with all other Schedule C customers under paragraph E below.
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Baltimore Gas and Electric Company
Natural Gas Curtailment Plan
D.
Marketing & Energy Service will notify Schedule IS and AIS customers that Critical Use
gas is curtailed. Any gas used will be charged to the Customer at the Curtailment
Penalty Rate. The Availability provision of both Schedules IS and AIS require the
Customer to have installed and maintained complete and adequate standby equipment
for operation with another fuel. Any Critical Use will, therefore, be supplied by the
Customer’s alternate fuel equipment.
E.
Customer Care and Marketing & Energy Services will notify large Schedule C
(classification CL) customers that gas use is curtailed to Critical Use levels. Critical Use
gas in excess of Transportation Gas arriving at the City Gate will be billed at the
Production Rate. Any gas used in excess of Critical Use levels will be charged to the
Customer at the Curtailment Penalty Rate.
F.
Corporate Communications, with assistance from Customer Care, will notify all
remaining Schedule C customers using pre-approved messages that gas use is
curtailed. Any gas used will be charged to the Customer at the Curtailment Penalty
Rate.
G.
Corporate Communications, with assistance from Customer Care, will notify residential
customers using pre-approved messages that gas use is curtailed. Concurrently,
Marketing & Energy Services will notify all remaining customers with Critical Use gas
that their Critical Use is curtailed.
IV.
Area Curtailment – Where immediate action is required to protect distribution system
reliability and sufficient time is not available to implement the Curtailment Hierarchy detailed
above, gas service to specific areas of the distribution system will be shut-off resulting in
complete curtailment of all customers within the area. The Company will make every effort to
avoid and, if necessary, to minimize this extreme action.
A.
Gas Planning & Engineering will pre-identify and maintain a hierarchy of areas to be
shut-off. This hierarchy will be developed to affect the smallest number of customers
while maintaining service to the largest number of customers.
B.
The disconnection of segments of the distribution system will be accomplished by
Pressure Control crews closing “emergency” valves at selected points in the distribution
system.
V.
Payment for Transportation Gas – Any Transportation Gas arriving at the
Company’s City Gate in excess of Critical Use for a Customer that has been curtailed will be reallocated for Company system use for those customers remaining. The Company will pay the
Customer or the Marketer, whichever is appropriate, for the re-allocated gas at the higher of the
Production Rate or the Transcontinental Gas Pipeline Company (Transco) Zone 6 (non-New
York) average daily price during the period of curtailment.
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