XXXX. Bremner Trio Small Hydro Project. Interconnection System Impact Study

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1 XXXX Bremner Trio Small Hydro Project Report No. August 2010 British Columbia Hydro and Power Authority British Columbia Hydro and Power Authority All rights reserved..

2 DISCLAIMER OF WARRANTY, LIMITATION OF LIABILITY This report was prepared by the British Columbia Hydro And Power Authority ( BCH ) or, as the case may be, on behalf of BCH by persons or entities including, without limitation, persons or entities who are or were employees, agents, consultants, contractors, subcontractors, professional advisers or representatives of, or to, BCH (individually and collectively, BCH Personnel ). This report is to be read in the context of the methodology, procedures and techniques used, BCH s or BCH s Personnel s assumptions, and the circumstances and constraints under which BCH s mandate to prepare this report was performed. This report is written solely for the purpose expressly stated in this report, and for the sole and exclusive benefit of the person or entity who directly engaged BCH to prepare this report. Accordingly, this report is suitable only for such purpose, and is subject to any changes arising after the date of this report. This report is meant to be read as a whole, and accordingly no section or part of it should be read or relied upon out of context. Unless otherwise expressly agreed by BCH: 1. any assumption, data or information (whether embodied in tangible or electronic form) supplied by, or gathered from, any source (including, without limitation, any consultant, contractor or subcontractor, testing laboratory and equipment suppliers, etc.) upon which BCH s opinion or conclusion as set out in this report is based (individually and collectively, Information ) has not been verified by BCH or BCH s Personnel; BCH makes no representation as to its accuracy or completeness and disclaims all liability with respect to the Information; 2. except as expressly set out in this report, all terms, conditions, warranties, representations and statements (whether express, implied, written, oral, collateral, statutory or otherwise) are excluded to the maximum extent permitted by law and, to the extent they cannot be excluded, BCH disclaims all liability in relation to them to the maximum extent permitted by law; 3. BCH does not represent or warrant the accuracy, completeness, merchantability, fitness for purpose or usefulness of this report, or any information contained in this report, for use or consideration by any person or entity. In addition BCH does not accept any liability arising out of reliance by a person or entity on this report, or any information contained in this report, or for any errors or omissions in this report. Any use, reliance or publication by any person or entity of this report or any part of it is at their own risk; and 4. In no event will BCH or BCH s Personnel be liable to any recipient of this report for any damage, loss, cost, expense, injury or other liability that arises out of or in connection with this report including, without limitation, any indirect, special, incidental, punitive or consequential loss, liability or damage of any kind. British Columbia Hydro and Power Authority, All rights reserved ii

3 COPYRIGHT NOTICE Copyright and all other intellectual property rights in, and to, this report are the property of, and are expressly reserved to, BCH. Without the prior written approval of BCH, no part of this report may be reproduced, used or distributed in any manner or form whatsoever. British Columbia Hydro and Power Authority, All rights reserved. iii

4 Executive Summary The XXXX, the Interconnection Customer (IC), proposes to develop the Bremner Trio Small Hydro Project in the Upper Harrison area in British Columbia to deliver electric energy to BC Hydro (BCH) through the BCH 2008 Clean Power Call (CPC). This report identifies the required system modifications for interconnecting the proposed Bremner Trio Small Hydro Project. The project consists of two generating stations: Bremner Creek generating station and Trio Creek generating station. The maximum power injection into the system is 49.5 MW at the Point of Interconnection (POI) at the BCH s Upper Harrison Terminal substation (UHT). The proposed Commercial Operation Date (COD) is March 1, To interconnect the Bremner Trio Small Hydro Project and its facilities into the BCH Transmission System at the POI, this System Impact Study (SIS) has identified the following issues and requirements: Add one 360 kv circuit breaker (3CB5) and associated switching facilities and create a line termination position at UHT Substation for the IC. Generation shedding at IPP is required to mitigate the facility thermal overloading under various contingencies. The required contingency signals to shed the IPP clusters are the same as those required in the existing Bridge River generation shedding scheme. The existing transmission lines 3L2 and 3L5 line protections will need to be modified at associated substations: BRT, ROS and UHT. A current differential protection will be used for the protection of the short line between UHT and the IPP 360 kv plant (< 0.5 km). The IC needs to provide a Class 2 or better communications link between its 360 kv station and UHT. The IC is also required to provide the required telemetry and status information, which is to be reported to BCH s Fraser Valley Office and Southern Interior Office. Fibre optic termination equipment and modems at UHT will be required. Function upgrades associated with system controls, SCADA, and EMS will be required at BCH s Fraser Valley Office and Southern Interior Office. Preliminary study indicates that the voltage sag at UHT when energizing the customer s 138/360 kv transformer will likely exceed limits stated in the BCH kv Technical Interconnection Requirements for Power Generators (TIR). A transformer inrush control scheme, such as a point-on-wave controller with independent controlled breaker phases, or pre-insertion resistors, might be required. The IC needs to provide appropriate studies to examine the necessity of an inrush mitigation scheme. The non-binding good faith cost estimate for interconnection Network Upgrades required to interconnect the proposed project to the BCH Transmission System is $6.9 million. The estimated time to construct the Network Upgrades required to interconnect the project to the BCH Transmission System is estimated at 18 months. Upgrades that are common to the other IPP projects in this area are not included in this report. British Columbia Hydro and Power Authority, All rights reserved. iv

5 Table of Contents DISCLAIMER OF WARRANTY, LIMITATION OF LIABILITY... ii COPYRIGHT NOTICE... iii Executive Summary...iv 1.0 Introduction Purpose of Study Terms of Reference Assumptions System Studies Steady State Pre-outage Power Flows Power Flow Based First Contingency Study Transient Stability Study Islanding Fault Analysis Analytical Studies Protection and Control & Telecommunications & Circuit Breakers Black Start Capability Transmission Line Upgrade Requirements Additional BCH Station Upgrades/Additions Other Issues Cost Estimate and Schedule Conclusion & Discussion...12 Appendix A Bremner Trio Small Hydro Model and Data...13 British Columbia Hydro and Power Authority, All rights reserved. v

6 1.0 Introduction The project reviewed in this System Impact Study report is as described in Table 1 below. Table 1: Summary Project Information Project Name Bremner Trio Small Hydro Project Interconnection Customer (IC) XXXX Point of Interconnection (POI) BCH s UHT substation IC Proposed COD March 1, 2015 Type of Interconnection Service NRIS ERIS Maximum Power Injection (MW) 49.5 (Summer) 49.5 (Winter) Number of Generator Units 4 Plant Fuel Hydro The XXXX, the Interconnection Customer (IC), proposes to develop the Bremner Trio Small Hydro Project consisting of two generating stations (Bremner Creek and Trio Creek) in the Upper Harrison area in British Columbia to deliver electric energy to BC Hydro (BCH) through the BCH 2008 Clean Power Call (CPC). The Bremner Creek generating station will be connected to a customer-owned 138 kv / 360 kv step up transformer station, via a 17 km customer-owned 138 kv transmission line, and then connect to BCH s Upper Harrison Terminal (UHT) via a very short customer owned 360 kv transmission line. Trio Creek generating station will have no direct link to the Transmission System, and will be connected to the Bremner Creek generating station via a 6 km customerowned 138 kv transmission line. The proposed maximum power to be injected into the BCH system from the project is 49.5 MW, which includes: - Bremner Creek generating station consisting of two 13.9 MVA unit with the rated power factor of 0.9 lagging, and - Trio Creek generating station consisting of two 11.1 MVA units with the rated power factor of 0.9 lagging. The Point of Interconnection (POI) is at UHT. The proposed final Commercial Operation Date (COD) is March 1, Figure 1 shows the one line diagram of the Bremner Creek generating station and the Trio Creek generating station and the connection to UHT. Figure 2 shows the regional transmission system with the interconnection of the IPP. British Columbia Hydro and Power Authority, All rights reserved. Page 1 of 14

7 Figure 1 Bremner Trio Small Hydro Project One Line Diagram and Interconnection to UHT British Columbia Hydro and Power Authority, All rights reserved. Page 2 of 14

8 Figure 2 Bridge River Regional Transmission System with the interconnection of the IPP 2.0 Purpose of Study The purpose of this SIS is to assess the impact of the interconnection of the proposed project on the BCH Transmission System. This study will identify constraints and Network Upgrades required for the reliable operation of the Transmission System. 3.0 Terms of Reference This study investigates and addresses the voltage and overloading issues of the transmission networks in the vicinity of the Bremner Trio Small Hydro Project as a result of the proposed interconnection. Topics studied include equipment thermal loading and rating requirements, system transient stability and voltage stability, transient over-voltages, protection coordination, operation flexibility, telecom requirements and high level remedial action scheme requirements. BCH planning methodology and criteria are used in the studies. British Columbia Hydro and Power Authority, All rights reserved. Page 3 of 14

9 The SIS does not investigate the operating restrictions and other factors for the possible second contingency outages. Subsequent internal network studies will determine the requirements for reinforcements or operating restrictions/instructions for those kinds of events. Impact to the bulk transmission system is not included in the SIS and will be covered in a separate study. The work necessary to implement the network improvements identified in this SIS report will be described in greater detail in the Interconnection Facilities Study report for this project. For any individual project that has its own staging developments, the impacts of the staging developments are not considered in the SIS. Only the final stage has been studied. 4.0 Assumptions The power flow conditions studied are base cases that include generation, transmission facilities, and load forecast representing the queue position applicable to this project. Applicable seasonal conditions and the appropriate study years for the study horizon are also incorporated. The 2015 heavy winter, heavy summer and light summer load flow base cases were selected for this study. The study is based on the model and data information provided by the proponent in the Generator Interconnection Data Form for this project. Reasonable assumptions are made to complete the study and the report, whenever such information is unavailable. 5.0 System Studies Power flow, short circuit and transient stability studies were carried out to evaluate the impact of the proposed interconnection. Studies were also performed to determine the protection, control and communication requirements, and to evaluate possible over-voltage issues. 5.1 Steady State Pre-Outage Power Flows Pre-outage power flows are prepared to assess the impact of the proposed interconnection using three basic system load conditions: 2015 winter peak load, 2015 summer light load and 2015 summer peak load, and defined generation conditions. Table 2 provides the power flow study results for the proposed interconnection. British Columbia Hydro and Power Authority, All rights reserved. Page 4 of 14

10 Table 2: Steady-state Pre-outage Power Flow Study Results IPP Output (MW) 2L90 ROS T1 2L3 2L9 2L13 2L14 No Year Big Silver /Shovel NW Stave Tretheway Upper Lillooet Bremner/ Trio Peace Gen SI gen LM gen (no new IPPs) MW MW MW MW MW MW HW N/A FULL Low Max A 2015HW N/A FULL Max LS N/A 19.3 N/A Low Max HS N/A 19.3 N/A Low full max A 2015HS N/A 19.3 N/A Full low max LS N/A 19.3 N/A N/A N/A low Balance Max Note: (1). Definition for system load conditions: LS: light summer load HW: heavy winter load HS: heavy summer load (2). Summer ratings (@30ºC ambient temperature) for the concerned transmission lines/transformer: 2L90: 396 MVA 2L3: 396 MVA 2L9: 390 MVA 2L13: 358 MVA 2L14: 338 MVA ROS T1: 450 MVA (3). The following system conditions have been set for this SIS: BC to US export transfer level: 230 MW RTA to BCH export transfer level: 380 MW British Columbia Hydro and Power Authority, All rights reserved. Page 5 of 14

11 The steady-state power flow studies have indicated: No voltage violations observed. No circuits overloaded 5.2 Power Flow Based First Contingency Study Power flow based single contingency (N-1) studies have been conducted to check if the post-disturbance performance including bus voltage deviation and facility loading meets the planning criteria under different system load conditions including heavy winter, heavy summer and light summer. The studies of the single contingency outage situations have indicated that there are some transmission equipment over-loading problems and voltage violation conditions due to the addition of the Bremner Trio Small Hydro Project. Generation shedding at the Bremner Trio s collecting bus is required in order to remove the over-loading problem and/or voltage violation conditions. The contingency study results without applying generation shedding based on 2015 heavy winter, 2015 heavy summer, and 2015 light summer load conditions are listed in Table 3, Table 4, and Table 5. Table 3: Contingency Study Results Overload in 2015 HW Case (Pre-outage condition: System Normal) (Bremner/Trio Small Hydro Project: COD of March 1, 2015 and Upper Lillooet Cluster: COD of August 1, 2015) From Bus To Bus O/L Current Rating Loading Cont. Name ID facility (A) (A) (%) No. Name No. Name Suggested Solutions 2L13(CKY-CYP) + CYP T2 201 CKY LYN 2T1 1 2L Gen shed at Upper Lillooet is required. 2L78 (ROS-ALZ) + ROS T1 + ALZ T3/T BRT 360 BRT 2T and 1809 and BRT T4 BRT T Bremner/Trio has to be integrated into the existing BR gen shed scheme. 2L9 (CKY-LYN) + LYN T1 201 CKY CYP 2T2 1 2L See the suggested solutions for loss of 2L13 3L5 UHT-ROS 1309 BRT and BRT T BRT 2T and BRT T Bremner/Trio and Upper Lillooet have to be integrated into the existing BR gen shed scheme. British Columbia Hydro and Power Authority, All rights reserved. Page 6 of 14

12 Table 4: Contingency Study Results Overload in 2015 HS Case (Pre-outage condition: System Normal) (Bremner/Trio Small Hydro Project: COD of March 1, 2015 and Upper Lillooet Cluster: COD of August 1, 2015) From Bus To Bus O/L Current Rating Loading Cont. Name ID facility (A) (A) (%) No. Name No. Name Suggested Solutions 2L13(CKY-CYP) CKY LYN 2T1 1 2L CYP T2 213 WLT LYN 2T2 1 2L Gen shed at Upper Lillooet is required. 201 CKY LYN 2T1 1 2L CKY CYP 2T2 1 2L L78 (ROS-ALZ) WLT LYN 2T2 1 2L ROS T1 + ALZ 1309 BRT and BRT T Bremner/Trio has to be integrated into the T3/T BRT 2T and BRT T existing BR gen shed RAS scheme. 2L77 ALZ-CBN + ALZ T2 + CBN T3/T BRT 360 BRT 2T and 1809 and BRT T4 BRT T See the suggested solutions for loss of 2L78 2L9 (CKY-LYN) CKY CYP 2T2 1 2L LYN T ROS and ROS T See the suggested solutions for loss of 2L13 2L17 (LYN-WLT) + LYN T2 201 CKY CYP 2T2 1 2L See the suggested solutions for loss of 2L13 2L14 CYP-WLT 201 CKY LYN 2T1 1 2L See the suggested solutions for loss of 2L BRT and BRT T Bremner/Trio and Upper Lillooet have to be integrated into the existing BR gen shed 3L2 BRT-UHT 1409 BRT 2T and BRT T scheme. 201 CKY LYN 2T1 1 2L CKY CYP 2T2 1 2L Bremner/Trio and Upper Lillooet have to be 1309 BRT and BRT T integrated into the existing BR gen shed 3L5 UHT-ROS 1409 BRT 2T and BRT T scheme. 201 CKY LYN 2T1 1 2L CKY CYP 2T2 1 2L ROS and ROS T L90 BRT-KLY 1207 ROS and ROS T Bremner/Trio and Upper Lillooet have to be integrated into the existing BR gen shed scheme. British Columbia Hydro and Power Authority, All rights reserved. Page 7 of 14

13 Table 5: Contingency Study Results Overload in 2015 LS Case (Pre-outage condition: System Normal) (Bremner/Trio Small Hydro Project: COD of March 1, 2015, and Upper Lillooet Cluster: COD of August 1, 2015) Cont. Name From Bus To Bus ID O/L facility Current Rating Loading (A) (A) (%) No. Name No. Name Suggested Solutions 106 SEC PHR L35_SEC L13(CKY-CYP) 201 CKY LYN 2T1 1 2L CYP T2 213 WLT LYN 2T2 1 2L Gen shed at Upper Lillooet is required. 201 CKY LYN 2T1 1 2L CKY CYP 2T2 1 2L L78 (ROS-ALZ) 213 WLT LYN 2T2 1 2L ROS T1 + ALZ 1309 BRT and BRT T Bremner/Trio has to be integrated into the T3/T BRT 2T and BRT T existing BR gen shed scheme. 2L77 ALZ-CBN CKY LYN 2T1 1 2L ALZ T2 + CBN 1309 BRT and BRT T T3/T BRT 2T and BRT T See the suggested solutions for loss of 2L MSA PHR L35_MSA L9 (CKY-LYN) SEC PHR L35_SEC LYN T1 201 CKY CYP 2T2 1 2L See the suggested solutions for loss of 2L MSA PHR L35_MSA L17 (LYN-WLT) 106 SEC PHR L35_SEC LYN T2 201 CKY CYP 2T2 1 2L See the suggested solutions for loss of 2L CKY LYN 2T1 1 2L L14 CYP-WLT 213 WLT LYN 2T2 1 2L See the suggested solutions for loss of 2L BRT and BRT T Bremner/Trio and Upper Lillooet have to be integrated into the existing BR gen shed 3L2 BRT-UHT 1409 BRT 2T and BRT T scheme. 201 CKY LYN 2T1 1 2L WLT LYN 2T2 1 2L BRT and BRT T L5 UHT-ROS 1409 BRT 2T and BRT T CKY LYN 2T1 1 2L CKY CYP 2T2 1 2L WLT LYN 2T2 1 2L ROS and ROS T L90 BRT-KLY 1207 ROS and ROS T Bremner/Trio and Upper Lillooet have to be integrated into the existing BR gen shed RAS scheme. Bremner/Trio and Upper Lillooet have to be integrated into the BR gen shed scheme. British Columbia Hydro and Power Authority, All rights reserved. Page 8 of 14

14 5.3 Transient Stability Study A series of transient stability studies under various system operating conditions including the heavy winter case, the heavy summer case, and the most severe light summer case have been performed. The model of the generating project was based on the IC s data submission plus additional assumptions where the IC s data was inadequate. The models and data values of the key components are shown in Appendix A. No transient stability issue has been observed at Bridge River area based on the interconnection of the Bremner Trio project. 5.4 Islanding Islanded operation is normally not an acceptable practice in BCH. Power quality protection will be required at the generating units to detect abnormal system conditions such as under/over voltage and under/over frequency and subsequently trip the units. The settings of these protective relays must conform to the existing BCH practice for generating plants so that the generator will not trip during normal ranges of voltages and frequencies. 5.5 Fault Analysis The short circuit analysis for the CPC System Impact Studies is based upon the latest BCH system short circuit model, which includes project equipment and impedances provided by the successful CPC Interconnection Customers. The model includes higher queued projects and planned system reinforcements but excludes the Northwest Transmission Line (NTL) and other lower queued projects. At this stage, the report does not provide Thevenin impedances at the Point of Interconnection (POI) due to uncertainties associated with the system reinforcement options identified for the CPC projects and the statuses of higher queued projects. However, these Thevenin impedances, including the ultimate fault levels at POI, will be made available to Interconnection Customers upon request. BC Hydro will work with the IC to provide accurate data, as required, during the project design phase. 5.6 Analytical Studies Preliminary calculations indicate that the voltage sag at UHT from energizing the customer s 138/360 kv transformer will likely exceed limits stated in the TIR. A transformer inrush control scheme, such as a point-on-wave controller with independent controlled breaker phases, or pre-insertion resistors, might be required. The IC will be British Columbia Hydro and Power Authority, All rights reserved. Page 9 of 14

15 responsible for undertaking the appropriate studies required to determine the necessity of an inrush mitigation scheme. If only a single Trio 10 MVA unit is in service (Bremner not in service), and the UHT end of the 138 kv line is opened by local or supervisory control (no fault conditions), there might be a temporary overvoltage due to interaction between the Trio source impedance and the charging capacitance of the 23 km of overhead line. It is the IC s responsibility to ensure security of its facilities for these types of scenarios. 5.7 Protection and Control & Telecommunications & Circuit Breakers Protection and Control As the circuit between UHT and the IPP 360 kv station is very short (< 0.5 km), a current differential protection will be used for the protection of this line. This protection will require digital communications between UHT and the IPP 360 kv terminal as well as an identical protection installed at the IC 360 kv terminal. BC Hydro practice is to use SEL-311L type relay for short line applications. Review 3L2 and 3L5 protection and revise settings at BRT, UHT and ROS. The IC will provide entrance protection, power quality protection and protection for the line from its 360 kv station to UHT and out of step protection as well in accordance with the TIR. The IPP will provide protection which will achieve tripping of faults in the IPP s installation within the clearing time of 8 cycles or less. The IC will provide the required telemetry and status information to be reported to BCH s Fraser Valley Office and Southern Interior Office via continuous communications. The IC is responsible for providing a continuous SCADA telecom link from their site to the closest BCH station with appropriate telecom facilities Telecommunications Install required fibre optic termination equipment and modems at UHT. Install required communication interface cards at existing DACS equipment at UHT, BRT and ING. Install tele-protection equipment to be used for the required Primary and Standby transfer trips for generator shedding from BRT to UHT. Install tele-protection equipment at BRT for the required Primary and Standby Genshed signals to the IPP. The IPP will supply and install a Class 2 communications link between their site and UHT. The IPP will also supply and install the telecom equipment and the teleprotection equipment at their site. British Columbia Hydro and Power Authority, All rights reserved. Page 10 of 14

16 All telecom and tele-protection equipment used by the IPP will be compatible with the standard telecom equipment specified by BCH. 5.8 Black Start Capability BCH does not require the proposed project to have black start (self-start) capability. However, if the IC desires their facilities to be energized from the BCH system, the IC is required to apply for an Electricity Supply Agreement. Upon receipt of this application, a plant pick-up study would be required to assess the impact of energizing the IC s facilities. A high level plant pick-up screening was performed as part of the SIS and any issues are identified in Section Transmission Line Upgrade Requirements No transmission line work required BCH Station Upgrades/Additions The UHT substation has already been developed to its ultimate stage (360 kv, 4-breaker ring). A new 360 kv position needs to be created for Bremner Trio. This is to be done by adding a 360 kv circuit breaker at the middle of the bus 3B1. This will avoid the need to acquire additional property but may restrict further expansion of the substation. Add one 360 kv circuit breaker and associated switching facilities Other Issues There are no other issues identified at this stage Cost Estimate and Schedule The non-binding good faith cost estimate for interconnection Network Upgrades required to interconnect the proposed project to the BCH Transmission System is $6.9 million. The Facilities Study Report will provide more accurate information of the cost estimates. The time to construct the Network Upgrades required to interconnect the project to the BCH Transmission System is estimated at 18 months after the Standard Generation Interconnection Agreement is signed and a BCH capital project is approved. A more detailed construction time line will be provided in the Facilities Study Report. British Columbia Hydro and Power Authority, All rights reserved. Page 11 of 14

17 BCH system upgrades triggered by CPC projects are being determined and the IC may be required to post security to cover one or more upgrade. Further information will be provided over the next few months. 6.0 Conclusion & Discussion To interconnect the Bremner Trio Small Hydro Project and its facilities into the BCH Transmission System at UHT, this System Impact Study has identified the following issues and requirements: Add one 360 kv circuit breaker (3CB5) and associated motor operated disconnect switches (3D1/D2CB5) and create line termination position at Upper Harrison Terminal (UHT) Generation shedding at Bremner Trio Small Hydro is required to mitigate the facility thermal overloading under various contingencies. The required contingency signals to shed the IPP clusters are the same as those required in the existing Bridge River generation shedding scheme The existing transmission lines 3L2 and 3L5 line protection modifications will be required at associated substations BRT, ROS and UHT A current differential protection will be used for the protection of the short line between UHT and the IPP 360 kv station (< 0.5 km) IC needs to provide a broadband Class 2 or better communications link between their 360 kv station and UHT. In addition, the IC is required to provide the required telemetry and status information, which is to be reported to BCH system control centers FVO and SIO Fibre optic termination equipment and modems at UHT will be required Functional upgrades associated with system controls, SCADA, and EMS will be required at BCH system control centers FVO and SIO Islanded operation of IPP is not allowed. Power quality protection is required to prevent/mitigate possible islanded operation Preliminary study indicates that the voltage sag at UHT from energizing the customer s 138/360 kv transformer will likely exceed limits stated in the TIR. A transformer inrush control scheme, such as a point-on-wave controller with independent controlled breaker phases, or pre-insertion resistors, might be required. The IC will be responsible for undertaking the appropriate studies required to determine the necessity of an inrush mitigation scheme. British Columbia Hydro and Power Authority, All rights reserved. Page 12 of 14

18 Appendix A IPP Model and Data Bremner / Trio Small Hydro The contents of this section have been removed due to the proprietary nature of the information. British Columbia Hydro and Power Authority, All rights reserved. Page 13 of 14

19 The contents of this section have been removed due to the proprietary nature of the information. British Columbia Hydro and Power Authority, All rights reserved. Page 14 of 14

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