MINIMUM OIL BURN/AUTOMATIC FUEL SWAPPING CAPABILITY

1.0 PURPOSE... 2 2.0 MINIMUM OIL BURNING/AUTOMATIC FUEL SWAPPING CAPABILITY NOTIFICATIONS... 3 3.0 MINIMUM OIL BURNING/AUTOMATIC FUEL SWAPPING CAPABILITY CRITERIA... 5 4.0 MINIMUM OIL BURNING/AUTOMATIC FUEL SWAPPING CAPABILITY GENERAL INFORMATION... 7 5.0 GAS SYSTEM EMERGENCY... 11 6.0 REFERENCES... 11 APPENDIX A... 12 APPENDIX B... 13 Approved Author Date SOP Number Supersedes Page 1 of L. Maiocco H. Wysocki System Operator

1.0 PURPOSE 1.1 To comply with the application of the Con Edison specific local reliability rule on the loss of gas supply to generation in NYC, it is required that during forecasted high electric system load days certain in-city generators must maintain either a minimum level of oil as part of the generator fuel burn mixture, or have the ability to automatically swap to a liquid fuel source to guard against the sudden interruption of gas fuel supply to the generator. 1.1.1 The term minimum oil burn is the amount of oil that the generation owner specifies is required to keep their unit on line at any given load level, upon the sudden and precipitous loss of gas fuel pressure. Typically this is provided as a ratio of oil to gas fuel or a percentage of oil to total fuel. 1.1.2 The term automatic fuel swapping capability is a system and associated equipment that gives a generator the ability to automatically switch from a gas fuel supply to a oil fuel supply, upon the sudden and precipitous loss of gas fuel pressure without interrupting the electric generation output of the unit. 1.2 Changes in system conditions or other circumstances may require that Con Edison, with NYISO review and approval, revise or add to the existing applications listed in paragraph 3.1 of this procedure. 1.2.1 The applications listed in paragraph 3.1 of this procedure shall be consistent with the applications listed in the NYISO Technical Bulletin # 159 Applications of the NYSRC Reliability Rules and Local Reliability Rules. 1.2.2 A current copy of this procedure is required to be on file with the NYISO, therefore, if any revision is made to this procedure, a copy of the revised procedure shall be sent immediately to the Manager, NYISO Reliability Compliance Assessment. 1.3 The Energy Dispatcher Generation Desk (ED-GD) shall report to the NYISO when generating stations are requested to comply with any of the actions required by this procedure, and any non-compliance by the generating stations to the actions required by this procedure. Date SOP Number Supersedes Page 2 of

1.4 All actions taken under this procedure, including the notifications to the NYISO and the generating stations, shall be recorded in the NYISO Min Oil Burn Log. The Energy Dispatcher shall upload min oil burn data to the NYISO from the Min Oil Burn Log as required. 1.5 Generators shall advise System Operation of any environmental constraints that will prevent their compliance with this procedure. 1.6 System Operation shall not require a generator to violate its environmental constraints when implementing this procedure. 2.0 MINIMUM OIL BURNING/AUTOMATIC FUEL SWAPPING CAPABILITY NOTIFICATIONS 2.1 The Senior System Operator (SSO) shall determine by 0300 hours of the day before the actual operating day that there is a need to declare a minimum oil burn/automatic fuel swapping capability day for the following operating day based on the projected electric system load for the NYC Zone J load zone, and the criteria set forth in paragraph 3.1 of this procedure. 2.1.1 System Operation uses an Artificial Neural Network (ANN) load forecasting tool to predict and track the daily and hourly Con Edison control area electric load forecast. 2.1.2 The NYC-Zone J load will be the multiplication of the forecasted load for the entire Con Edison electric control area by an 87% factor, as determined by the NYISO. 2.2 If the forecasted electric load indicates that there is a need to declare a minimum oil burn/automatic fuel swapping capability day the following operating day, the SSO will advise the CIG Information Specialist and request that all affected generating stations be notified via the Computerized Notification System (CNS) and/or other means. This is being done to allow the affected generating stations sufficient time to adjust their generation bids prior to the close of the NYISO Day Ahead Market (DAM). 2.3 By 0400 hours, the CIG Information Specialist shall use the CNS and/or other means to inform all affected generating facilities that a minimum oil burn/automatic fuel swapping capability day is forecasted for the next operating day by stating that - "Tomorrow (announce the day and date), System Operation is forecasting to be a minimum oil burn/automatic fuel swapping capability day. System Operation will notify you by 0400 hours of the operating day that an Date SOP Number Supersedes Page 3 of

actual minimum oil burn/automatic fuel swapping capability day has been declared. At this time you are not expected to actually make any changes to your generator s fuel mixture but if necessary you should ensure that the automatic fuel swapping capability of your unit is functionally ready. 2.3.1 With respect to contacting NYPA generating facilities, the ED-GD and the CIG Information Specialist shall telephone the NYPA System Operation Control Center at (315) 724 2300, and speak to their System Operator to make any notification. 2.4 When the operating day s forecasted electric system load exceeds one of the defined trigger points as given in paragraph 3.1 of this procedure, the following shall be done: 2.4.1 The System Operator (SO) on the 12-8 shift shall declare a minimum oil burn day/automatic fuel swapping capability day and shall notify the SSO, the ED-GD, the Gas System Operator (GSO), and the CIG Information Specialist. 2.4.2 The GSO will include the declaration of a minimum oil burn day/automatic fuel swapping capability day in the Gas Control Daily Report. 2.4.3 By 0400 hours, the CIG Information Specialist shall use the CNS and/or other means to inform all affected generating stations that a minimum oil burn/automatic fuel swapping capability day is in effect by stating that - " Today (announce the current day and date), System Operation is declaring a minimum oil burn/automatic fuel swapping capability day. You will be notified by the System Operator or the Energy Dispatcher Generation Desk when to actually change your generator s fuel mixture or to initiate the automatic fuel swapping capability of your unit. At this time you are not expected to actually make any changes to your generator s fuel mixture but if necessary you shall ensure that the automatic fuel swapping capability of your unit is functionally ready. 2.4.4 The CIG Information Specialist can deliver both notifications (day ahead and operating day) together provided the content of the messages are clearly stated separately. Date SOP Number Supersedes Page 4 of

2.4.5 [Section Deleted] - Information provided in section 3.0 of this procedure. 3.0 MINIMUM OIL BURNING/AUTOMATIC FUEL SWAPPING CAPABILITY CRITERIA 3.1 The following criteria shall be used to determine which generators need to be notified to actually meet the stated requirements of a minimum oil burn/automatic fuel swapping capability generation day. Winter Capability Period: 3.1.1 At NYISO forecasted "NYC - Zone J" load above 6500 MW (equivalent to Con Edison electric system forecasted loads above 7,500 MW) during the Winter Capability Period, minimum oil burn/automatic fuel swapping capability is required in one of the Astoria 138 kv units (3, 4, 5 OR NYPA CC1/CC2) connected to the Astoria West bus. 3.1.2 At NYISO forecasted "NYC - Zone J" load above 7000 MW (equivalent to Con Edison electric system forecasted loads above 8,000 MW) during the Winter Capability Period, minimum oil burn/automatic fuel swapping capability is required in two of the Astoria 138 kv units (3, 4, 5, NYPA CC1/CC2 OR Astoria Energy) with one unit connected to the Astoria East bus and the other connected to the Astoria West bus. 3.1.3 At NYISO forecasted "NYC - Zone J" loads above 7800 MW (equivalent to Con Edison electric system forecasted loads above 9000 MW) during the Winter Capability Period, "minimum oil burn/automatic fuel swapping capability" is required in two (2) of the Astoria 138 kv generating facilities with one unit each connected to the Astoria East and West buses. In addition one (1) Ravenswood unit is required to be on MOB if the Poletti generating station is not on-line. *note- Poletti not required on min oil. After Poletti retirement, one Ravenswood unit is required to be on MOB. 3.1.3.1 The Winter Capability Period, as used here, is defined to be from November 1 st to April 30 th. These dates are consistent with the definition for capability periods given the NYSRC Glossary of Terms. Date SOP Number Supersedes Page 5 of

Summer Capability Period: 3.1.4 At NYISO forecasted "NYC - Zone J" load above 7,850 MW (equivalent Con Edison forecasted electric system loads above 9,000 MW) during the Summer Capability Period, minimum oil burn/automatic fuel swapping capability is required in one of the Astoria 138 kv units (3, 4, or 5) connected to the Astoria West bus or NYPA CC1/2. 3.1.5 At NYISO forecasted "NYC - Zone J" load above 8,275 MW (Con Edison forecasted electric system loads above 9,500 MW) during the Summer Capability Period, minimum oil burn/automatic fuel swapping capability is required in two of the following units with one unit connected to the Astoria East bus and the other connected to the Astoria West bus: Astoria 138 kv units (3,4,or 5), Astoria Energy, NYPA CC1/2. 3.1.6 At NYISO forecasted "NYC - Zone J" load above 8,700 MW (Con Edison forecasted electric system loads above 10,000 MW) during the Summer Capability Period, additional "minimum oil burn capability" is required in one Ravenswood (1,2,3) generating facility. 3.1.7 At NYISO forecasted "NYC - Zone J" load above 9,575 MW forecasted (Con Edison forecasted electric system loads above 11,000 MW) during the Summer Capability Period, one East River unit, ER 6 or 7, must be on minimum oil burn. 3.1.8 At NYISO forecasted "NYC - Zone J" load above 10,000 MW (Con Edison forecasted electric system loads above 11,500 MW) during the Summer Capability Period, the Astoria Energy and NYPA CC1/CC2 generating facilities must be on automatic fuel swapping capability and Astoria 4 and 5, Ravenswood 1 or 2, Ravenswood 3 and East River 6 and 7 generating facilities must all be on minimum oil burn. 3.1.8.1 The Summer Capability Period, as used here is defined as from May 1 st to October 31 st and is consistent with the definition given in the NYSRC Glossary of Terms. Date SOP Number Supersedes Page 6 of

4.0 MINIMUM OIL BURNING/AUTOMATIC FUEL SWAPPING CAPABILITY GENERAL INFORMATION 4.1 The following information related to minimum oil burn and auto fuel swapping capability is provided on generating units: NYPA CC1/2 and Astoria Energy CC1/2 are combined cycle units designed with dual fuel capability (natural gas or liquid fuel), which have an obligation under their interconnection agreements to provide automatic fuel swapping capability. NYPA CC1&2 and Astoria Energy CC1&2 have a maximum number of gallons of liquid fuel which they can burn. The amount equates to approximately 30 days at full load. Ravenswood 4 is a combined cycle unit designed with dual fuel capability (natural gas or liquid fuel), but does not have an obligation to provide fuel swapping capability. Rav 4 would be ordered off gas in an emergency and could swap to liquid fuel. Ravenswood 4 does not have a designed low Gas Street Pressure trip, but would most likely experience problems at 190 PSIG. Ravenswood 4 has a maximum number of gallons of liquid fuel which they can burn. The amount equates to approximately 30 days at full load. Ravenswood 4 would have to reduce its output to approximately 15MW in order to conduct the manual swap. East River 1 & 2 are combined cycle units designed with dual fuel capability (natural gas or liquid fuel), but can only burn liquid fuel in an emergency. East River 1 & 2 have a low Gas Street Pressure trip at 175 PSIG. East River 1 & 2 may only operate for 16-hrs per year on liquid fuel. East River 1 & 2 could exceed their annual 16-hr limit if an emergency was declared. This declaration would only apply if a gas system emergency has been declared by the Gas Dispatcher, and the Gas Dispatcher has ordered these units off gas usage. The Senior System Operator would have to order both units off line to stop the gas consumption. At this point, depending on the impact to the steam and/or electric system an evaluation would be made to determine if the units should be brought back on line burning liquid fuel. The attachment in appendix A reflects the emissions permit guidelines and should be consulted in making this decision. Date SOP Number Supersedes Page 7 of

ER 7 shall not be requested to be in minimum oil burn during the period when it is committed as a steam only provider. Astoria generating units (3, 4 and 5), Poletti, Ravenswood generating units (1, 2 and 3), and East River generating units (6 and 7) all have dual fuel (natural gas and oil) and minimum oil burning capability. These generating units have a low gas street pressure trip system that will automatically shut off the gas supply when the gas street pressure falls below 150 PSIG. At Poletti, the low gas pressure trip setting is 100 PSIG. Astoria 2 and both Arthur Kill units (2 and 3) are not dual fuel burning units and can only run on gas. Astoria 2 is supplied gas from the Con Edison gas transmission system. Arthur Kill units are supplied gas from the KeySpan gas transmission system. Both sites have a low gas pressure trip system that will automatically trip the gas supply when the gas pressure falls below 150 PSIG at Astoria 2, and below 80 PSIG at the Arthur Kill site. All in-city NYPA gas turbines have only gas burning capability including those supplied from the KeySpan gas transmission system, and each has a low gas pressure trip system that will automatically trip the gas supply when the gas pressure falls below 150 PSIG. The NYPA Harlem River, Hellgate, and Vernon gas turbines are supplied from the Con Edison gas transmission system. All Astoria and Ravenswood quick start 10 minute gas turbines have an automatic fuel changeover feature which will swap fuel from gas to an alternate liquid fuel within 35 seconds when the gas pressure falls below 180 PSIG for the Astoria GT site, and 190 PSIG for the Ravenswood GT site. Note that the automatic fuel swap to liquid fuel is only useful for a gas turbine that is already online. The quick start gas turbines at both sites cannot start with liquid fuel only. They require some gas pressure to start. Narrows gas turbine barge 1 and 2, and Gowanus gas turbine barge 2 and 3 are dual fuel capable. Gowanus gas turbine barge 1 and 4 can only burn liquid fuel. Narrows and Gowanus dual fuel units have automatic fuel swap over to liquid fuel capability. At the Narrows site, the automatic swap over feature is initiated at the loss of gas pressure of 165 PSI. At the Gowanus site, the automatic swap over feature is initiated at the loss of gas pressure Date SOP Number Supersedes Page 8 of

of 150 PSI. Liquid fuel burning units at both the Narrows and Gowanus can start without the use of gas. 4.2 The SO and/or ED-GD shall determine when the electric system load is expected to reach one of the defined trigger points given in paragraph 3.1 of this procedure. At least three hours prior to that time, the appropriate generating stations identified in section 3.1 shall be notified that at XXX hrs, (the projected time Con Edison System Load is expected to reach the trigger point) the Unit is to be on minimum oil burn and/or to ensure the availability of their automatic fuel swapping capability, whichever is applicable, to prevent the loss of electric generation due to the sudden loss of gas fuel pressure. 4.3 The ED-GD shall also advise the appropriate generating stations that they must notify either the SO or ED-GD when the loss of gas fuel precautions have been implemented and/or verified. The ED-GD shall record this information in the NYISO Daily Report, and shall notify the NYISO. 4.4 The ED-GD will confirm the reduction in gas fuel consumption due to implementation of the requirements listed in paragraph 3.1 of this procedure, and continue to monitor the gas burn rate of the affected generators by using the Gas Operation SCADA System (GOSS) application provided on their PC. 4.4.1 The ED-GD will compare the actual hourly integrated gas flow rates provided in GOSS to the estimated gas flow rates at minimum oil burn that have been provided to the ED-GD in a look-up table. 4.5 The generation owners have specified the following amounts as the percentage of fuel oil to total fuel that their generating facilities need in order to meet the requirements of a minimum oil burn day. These percentages are applicable over the entire operating range of the units except for the NYPA Poletti unit percentage, which is valid at their minimum electric generation level only. Astoria units 3, 4, and 5-25% East River units 6 and 7-25% Ravenswood units 1, 2,and 3-30% Poletti - 20% Date SOP Number Supersedes Page 9 of

4.6 The ED-GD will use these percentage change figures to determine if the affected generators have reached and are maintaining the desired reduction in their gas fuel consumption rate. 4.7 If the desired reduction in gas fuel consumption rate is not achieved and/or maintained during a minimum oil burn/automatic fuel swapping day, the ED-GD shall contact the generating site to determine the reason, and advise the SSO and SO of the condition and reason for the generator s noncompliance. 4.7.1 The SO or the ED-GD shall advise the Gas System Operator of the generator s noncompliance in achieving and/or maintaining the desired reduction in gas fuel consumption rate. 4.7.2 The SSO shall contact the appropriate Plant Manager to confirm the problem and attempt to resolve the generator s noncompliance. The SSO shall advise the Chief System Operator of the situation. 4.7.3 The SSO shall determine if further notification to the NYISO is required regarding the generating unit s noncompliance. 4.8 The ED-GD shall notify the NYISO of the noncompliance, and make an entry note describing the generator s noncompliance and the reason for the noncompliance in the NYISO Daily Report including the fact that the NYISO was notified. 4.9 Each generating site shall be responsible to meet its minimum oil burn/automatic fuel swapping capability requirements one unit at a time to ensure that the NYISO dispatch requirements are met during the fuel changeover. 4.10 When the real time Con Edison system load level declines below the load levels listed in paragraph 3.1, the ED-GD, with the permission of the SO, shall order all units involved in the "minimum oil burn /automatic fuel swapping capability" day to return to their desired fuel mixture or preferred fuel arrangement. 4.11 The SO and/or the ED-GD shall notify the NYISO that the minimum oil burn/automatic fuel swapping capability event has been terminated. The date and time of the termination, and of the notification to the NYISO, shall be recorded in the NYISO Daily Report. Date SOP Number Supersedes Page 10 of

5.0 GAS SYSTEM EMERGENCY 5.1 When the Gas System Operator (GSO) declares the operational status of the gas system as Gas System Condition Yellow or Red, the GSO shall immediately notify the SO. The GSO shall take the necessary corrective actions in response to the emergency, and depending on the nature of the gas condition, advise the SO of any specific assistance including the requirement to have dual fuel burning generating stations or stations with automatic fuel swapping capability to switch from gas to oil as quickly as possible. 5.1.1 Refer to Gas Engineering procedure G4905 - Guide for Major Contingencies on the Gas System for guidelines to be followed in the event of a major incident or contingency on the gas system. 5.1.2 Refer to System Operation procedure SO 5-36 - Gas System Emergency Coordinated Response Procedure for guidelines to be followed by electric, gas, and steam system operators during a contingency on the gas transmission system. 5.1.3 Combine-cycle type units such as KeySpan RAV 4, shall be told to actually swap fuels only if there is a gas system emergency. 5.2 The Gas Emergency Response Center shall advise the CIG Information Specialist of the gas system condition and any required notifications. 5.3 All actions or notification taken by the SSO, SO or ED shall be recorded in the NYISO Daily Report. 5.3.1 In recording the actions and notifications made to generating stations it is necessary to record both the time that the station was advised of the necessary step and the time that the step was completed by the station. 6.0 REFERENCES 6.1 SO5-36 Gas System Emergency Coordinated Response Procedure 6.2 NYISO Technical Bulletin #159 Applications of the NYSRC Reliability Rules and Local Reliability Rules Date SOP Number Supersedes Page 11 of

APPENDIX A Item 81.2 of the Air State Facility permit for the Project provides that "LOW SULFUR (0.045% MAXIMUM by weight) DISTILLATE OIL WILL BE FIRED IN THE COMBUSTION TURBINE. DISTILLATE OIL WILL ONLY BE USED DURING AN EMERGENCY (AS DEFINED IN 6 NYCRR 201-2.1(b)(12)) AND, UP TO 16 HOURS PER YEAR FOR TEST FIRING." Items 66.3 and 66.7 of the East River Title V permit provide for Project Unit Nos. 1 and 2, respectively, that "distillate oil will only be fired in an emergency (as defined in 6 NYCRR 201-2.1(b)(12) and test firing up to 16 hours per year." 6 NYCRR 201-2.1(b)(12) defines "Emergency" as "any situation arising from sudden and reasonably unforeseeable events beyond the control of the owner and /or operator of a facility, including acts of God, which situation requires immediate corrective action to restore normal operation and which causes the emission source to exceed a technology-based requirement under the permit or State-established emission limitations, due to unavoidable increases in emissions attributable to the situation. An emergency shall not include situations caused by improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error." Date SOP Number Supersedes Page 12 of

Low Gas Trip Setpoint Second Fuel MOB Capable APPENDIX B Auto Swap Capable Con Ed Gas System Astoria 2 150 None No No Astoria 3 150 Oil Yes - burns 25% oil No Astoria 4 150 Oil Yes - burns 25% oil No Astoria 5 150 Oil Yes - burns 25% oil No NYPA 500 190 Liquid Fuel N/A When aligned & charged swaps at 225 # Astoria Energy 180 Liquid Fuel N/A When aligned & charged swaps at 225 # Ravenswood 1 150 Oil Yes - burns 30% oil No Ravenswood 2 150 Oil Yes - burns 30% oil No Ravenswood 3 150 Oil Yes - burns 30% oil No Ravenswood 4 150 Liquid Fuel No No, at 15 MW manually swap Poletti 100 Oil Yes - burns 20% oil (at min electric output) No ER1 175 Liquid Fuel No No - Must shutdown to swap ER2 175 Liquid Fuel No No - Must shutdown to swap ER6 150 Oil Yes - burns 33% oil No ER7 - don't request MOB when on steam only 150 Oil Yes - burns 33% oil No Astoria Quickstart GT's (Ast None - fuel 5-8, 10-13 liquid only) swaps at 180 # Liquid Fuel N/A Yes - at 180 #, if online (need gas to start) Ravenswood Quickstart GT's (GT 3-3, 3-4 gas only) Liquid Fuel N/A Yes - at 190 #, if online (need gas to start) NYPA GT's - Hell Gate 150 None N/A No NYPA GT's - Harlem River 150 None N/A No NYPA GT's - Vernon 150 None N/A No Keyspan / National Grid Gas System Arthur Kill 2 80 None No No Arthur Kill 3 80 None No No Narrows GT Barge 1, 2 Liquid Fuel N/A Yes,165 # (starts on oil or gas) Liquid fuel Gowanus GT Barges 1, 4 only - no gas Liquid fuel only - no gas Gowanus GT Barges 2, 3 Liquid Fuel N/A Yes,150 # (starts on oil or gas) NYPA GT - Pouch 150 None N/A No NYPA GT's - Gowanus GT 5 & 6 150 None N/A No NYPA GT - North First/Kent 150 None N/A No BNY variable Liquid Fuel N/A Yes KIAC 180 None No No NJ Gas System Linden Cogen Butane (derates site) N/A Date SOP Number Supersedes Page 13 of