1.0 GENERAL... 2 2.0 DEFINITIONS... 3 3.0 THUNDERSTORM & TORNADO WARNING CRITERIA... 4 4.0 HURRICANE WARNING CRITERIA... 7 5.0 WINTER STORM WARNING CRITERIA... 9 6.0 PROCEDURE... 9 7.0 NOTIFICATIONS... 11 8.0 OPERATING CRITERIA DURING A THUNDERSTORM WARNING... 12 9.0 ADJUSTMENTS TO BE MADE IF THUNDERSTORM Warning POST CONTINGENCY LTE IS EXCEEDED AS DEFINED IN SECTION 8.0... 13 10.0 10.0 CONTINGENCIES OCCUR, AND THE LONG TIME EMERGENCY (LTE) OR SHORT TIME EMERGENCY (STE) RATINGS ARE EXCEEDED... 14 11.0 REFERENCES... 14 APPENDIX A... 15 APPENDIX B... 16 APPENDIX C... 17 Approved Author Date SOP Number Supersedes Page 1 of L. Maiocco M. Mian Chief System Operator External
1.0 GENERAL 1.1 This procedure is a guide and provides criteria to be followed by the Senior System Operator and System Operator during adverse weather conditions that can include Thunderstorms, Hurricanes, Tornados, or Snowstorms. 1.2 The following sources will provide information to System Operation concerning the threat of thunderstorms, tornadoes, or snowstorms. 1.2.1 Subscription Weather Service - Squall Line Forecast (advancing thunderstorms), winter storms - reported to the Central Information Group. 1.2.2 System Operation Staff Meteorologist 1.2.3 Westchester/Staten Island - Emergency Supervisors. 1.2.4 Substation or generating station personnel. 1.2.5 Neighboring utility personnel. 1.2.6 Lightning detection system 1.2.7 120 Hours (5 Days) in advance of the arrival of a major coastal storm, Emergency Management will notify the Senior System Operator when there is a reasonable probability that a major coastal storm could hit the Con Edison service territory. 1.3 The Subscription Weather Service determines the tracking, in time and direction, of the approaching storm, and also sends email notifications and/or makes phone calls to the Senior System Operator and CIG to notify the company of potential thunderstorm conditions. The Senior System Operator may request CIG to contact the Service for thunderstorm condition updates. 1.4 If a thunderstorm is detected, the Senior System Operator will generate the electronic Thunderstorm Warning Report Form accessed through the following link: \\m29001r1\sso_share\thunderstorm Warning Form\T-StormApp.mdb (Appendix A). If the link is inoperable, a hardcopy version of the form should be completed. This will be done for all thunderstorms reported by our subscription weather service even if a Thunderstorm Warning is not declared. 1.5 Refer to Appendix B for System Operation Pre-Season Hurricane Planning Requirements. Date SOP Number Supersedes Page 2 of
2.0 DEFINITIONS 2.1 A Thunderstorm Warning is when thunderstorms or tornadoes contain lightning of sufficient frequency that may pose a threat to our transmission facilities. A Thunderstorm Warning may also be declared when forest fires may affect significant transmission feeder corridors. 2.1.1 Under most circumstances, a Thunderstorm Warning declaration means that the storm activity is approaching the Con Edison service area and is expected within one hour. 2.1.2 An IMMEDIATE Thunderstorm Warning may be declared if the storm activity has developed without advance warning near the service territory or has already developed within the service territory. In this case, there is no one hour advance notice and the impacted substations shall be staffed as expeditiously as possible. 2.2 A Winter Storm Warning is when wet heavy snow with high winds or significant icing conditions is impacting our overhead transmission corridor. 2.2.1 Normal density is a snow to liquid ratio of 11:1 (1 inch of liquid makes 11 inches of snow) 2.2.2 High density snow is a snow to liquid ratio less than 8:1, this is considered a wet snow. 2.2.3 Low density snow has a snow to liquid ratio of greater than 15:1, this is considered a dry, powdery snow. 2.3 A Hurricane Warning is when hurricane conditions are forecasted by our subscription weather service to impact our area within a 36-hour period. 2.4 Major Transmission Facilities: All 345Kv overhead and underground lines/cables. 2.5 Major 345Kv transmission substations: In-City Mott Haven, Farragut, Rainey, West 49th Street, East 13th Street, Gowanus, Goethals, Fresh Kills. Northern Area East Fishkill, Pleasantville, Ramapo, Buchanan, Pleasant Valley, Millwood West, Dunwoodie, Sprain Brook. Date SOP Number Supersedes Page 3 of
2.6 Major 138KV/69kV Generation Output Facilities: Astoria Complex (Astoria East, Astoria West, North Queens Substations) Gowanus Substation (Gowanus Gas Turbine Barges) Greenwood Substation (Narrows Gas Turbine Barges, NYPA Gas Turbines)) Vernon Substation (Ravenswood, NYPA Gas Turbines) E13th Street/East River Substation 2.7 Light or isolated thunderstorm activity is defined by the subscription weather service as 1-15 lightning strikes per 30 minute time period for each thunderstorm cell. 3.0 THUNDERSTORM & TORNADO WARNING CRITERIA 3.1 Whenever possible, the Con Edison System Operator will provide a 2-hr advanced warning to the NYISO when weather forecasting resources indicate a high probability exists that storms will impact the area within the 2-hr period. The NYISO will use this notification to insure the most economical dispatch of generation resources is implemented such that all thunderstorm contingencies will be solved in advance of the storms arrival. The actual storm warning will still take place one hour in advance of the storm arrival. 3.2 A Thunderstorm Warning may be initiated by the NYISO after the System Operator notifies the NYISO of thunderstorm or tornado activity under the following guidelines: 3.2.1 Activity which is detected approximately two hours in advance of impacting the Con Edison service territory will require a heads up notification for a thunderstorm warning to be made to the NYISO and the Substation Shift Manager. A second call shall be made when the storms are one hour from the service territory to the NYISO and Substation Shift Manager to make the actual thunderstorm warning notification. The effected substations shall be staffed within one hour of the actual thunderstorm warning notification to the Substation Shift Manager. 3.2.2 Activity which is reported to be within one hour of and tracking toward the Con Edison service territory require a thunderstorm warning notification be made to the NYISO and Substation Shift Manager. It is required that substation personnel arrive to the proper stations within Date SOP Number Supersedes Page 4 of
one hour of the Substation Shift Manager being notified by the Bulk Power Team of the thunderstorm warning declaration. 3.2.3 Activity which is already on top of the service area or has already formed inside of the service area without warning will have an IMMEDIATE Thunderstorm Warning declaration issued to the NYISO and Substation Shift Manager. If declared in an IMMEDIATE basis, there will not be a one hour buffer for substation personnel to be moved to the affected stations. Personnel must be moved to staff the affected substations as expeditiously as possible 3.3 Category I Thunderstorm Warning - Thunderstorm or tornado activity which affects or is forecasted to affect the entire or a major portion of the Con Edison service area due to a major squall line or widespread severe weather. All major 345Kv transmission facilities that are out of service for scheduled work and are available shall be recalled. All major 345Kv transmission substations listed above shall be staffed. 3.3.1 The Astoria complex, which receives the output of Astoria units 3 and 5, NYPA CC1/CC2, Astoria Energy CC1/CC2 and Astoria Gas Turbines shall be staffed. The Vernon Substation which receives the output of Ravenswood units 1, 2 and 4 and NYPA GT s shall be staffed. East River substation shall be staffed. Gowanus and/or Greenwood substations shall be staffed, only if, gas turbines are on line or expected on line. 3.4 Category II Thunderstorm Warning - Thunderstorm or tornado activity which affects or is forecasted to affect an isolated portion of the Con Edison service area, such as, the Pleasant Valley area, Queens area or Staten Island area due to local storm activity. 3.4.1 Those major 345Kv transmission facilities that are out of service for scheduled work, are available, and are located in or directly supply the affected area shall be recalled. 3.4.2 In general, most local thunderstorm or tornado activity affects either the northern area or the in-city area of the Con Edison service territory. Therefore most Category II Thunderstorm Warnings will only require the staffing of Date SOP Number Supersedes Page 5 of
either the "In City" or "Northern Area" Major 345Kv transmission substations as outlined below. 3.4.3 Those major 345Kv substations that are located in the affected area shall be staffed. 3.4.4 The Astoria complex, Vernon Substation, Rainey Substation East River Substation, Goethals Substation, Gowanus Substation and/or Greenwood Substations shall be staffed only if they are located within the affected area. Gowanus and/or Greenwood Substations shall also be staffed if gas turbines are on line or expected on line. 3.5 The Con Edison Staff Meteorologist will provide a notification to the Substation Shift Manager at the beginning of each day if there is a 50% or greater chance of thunderstorms/lightning activity impacting the Northern area for any portion of the day. The Substation Shift Manager will then staff Ramapo and Pleasant Valley Substations during the appropriate shift since one hour notification is not adequate to insure coverage prior to the storms impacting these facilities. 3.6 When "light" or isolated thunderstorm activity is forecasted by the subscription weather service, the Senior System Operator has the option not to declare a Thunderstorm Warning. However, to obtain all available information prior to making this decision the Senior System Operator shall: Canvas Substation Operators in the effected areas for local reports of lightning activity. Review lightning detection system displays. Consult with the staff meteorologist, or the meteorologist from our subscription weather service for more specific information as to the frequency of lightning strikes. If any of the preceding, or other sources not listed indicate conditions more severe than light or isolated, a Thunderstorm Warning shall be immediately declared. The Senior System Operator also has the option to declare a Thunderstorm Warning without recalling any major 345Kv equipment or staffing any 345Kv substations if after consulting with the meteorologist, it is in his/her judgment the exposure to lightning strikes and the duration of storm activity is minimal. Date SOP Number Supersedes Page 6 of
3.7 Under certain conditions, augmented substation staffing without declaring a Thunderstorm Warning is required. 3.7.1 The Bulk Power Team shall notify the Substation Shift Manager of any special staffing requirements and the required personnel arrival times as the situation dictates. 3.7.2 Ramapo Substation shall be staffed for all Category 2 Thunderstorm Warnings for the Southern Area. Ramapo Substation shall also be staffed for thunderstorm/lightning activity occurring in Central and Northern New Jersey that exceeds a light level. Inter-utility tie feeder 5018 runs approximately 50 miles from PSEG s Hopatcong Substation in Hopatcong County, New Jersey to Ramapo Substation. 3.8 For category II thunderstorm warnings that do not affect the northern transmission corridor, thunderstorm contingency cases shall not be solved 3.9 Six Lines South Of Millwood: There are two transmission right of ways that run parallel for 4300 feet south of the Millwood station where double circuit towers associated with feeders Y86/Y87, W85/W82 and W99/W93 are in close proximity. When tornado activity or forest fires are forecasted to affect this transmission corridor a Category II Thunderstorm Warning is to be declared and all required actions are to be implemented. The following two additional actions shall also be implemented. 3.9.1 The "All Lines South of Millwood" Contingency case shall be activated. 3.9.2 System adjustments are to be made to limit the cable interface flow to 3000. 4.0 HURRICANE WARNING CRITERIA 4.1 As per the Corporate Coastal Storm Plan, at 120 hours (5 Days) prior to the arrival of a major coastal storm or hurricane, Emergency Management will notify the Senior System Operator. 4.2 At 48 hours (2 days) prior to a storm s arrival, Con Edison will enter the Storm Planning Phase. System Operations will determine the operational impact of the impending severe weather. Date SOP Number Supersedes Page 7 of
4.3 If our subscription weather service issues Hurricane Warnings, forecasts hurricane or major coastal storm conditions to impact our service area in the upcoming 36-hour period then a Hurricane Warning shall be declared by the Senior System Operator. 4.4 All operating criteria that are followed during a Category 1 Thunderstorm Warning will also be followed when a Hurricane Warning has been declared. 4.5 The Indian Point nuclear power generating facility has special operating requirements with regards to hurricane activity and may be required to come off line and be in some form of shutdown mode that depends on the severity and location of the hurricane. The requirements for unit 2 & 3 differ, and must be discussed with the plant s operations manager. 4.5.1 As soon as our subscribed weather service notifies us that a hurricane may impact our area, the Senior System Operator shall contact the Indian Point operations manager to ascertain the specific requirements and the plant s shutdown schedule should the hurricane affect the area. 4.5.2 The Senior System Operator shall then contact the NYISO and advise them of the shutdown requirements and of the need for the NYISO to arrange for replacement generating capacity. This should be done with as much advance notice as is possible, based on the hurricane s forecast. 4.5.3 Once a hurricane warning is declared, the Senior System Operator shall contact the Operations Manager and verify the plant s shutdown requirements and plans. The Senior System Operator shall then notify the NYISO and obtain information on the replacement generating capacity. The Senior System Operator shall also check the status of the Indian Point facility periodically as the hurricane is tracked. 4.6 The Senior System Operator shall direct the Energy Dispatchers to contact all electric and steam generating facilities in our control area and direct those facilities to initiate their flood control procedures in preparation for the storm. 4.6.1 The Energy Dispatcher shall contact all Combined Cycle Facilities with Air-Cooled Condensers, i.e. Astoria Energy I/II, NYPA 500, Ravenswood 4, and direct those facilities to report any abnormal operation of the Air-Cooled Condenser or decline in Steam Turbine Backpressure Date SOP Number Supersedes Page 8 of
(NOTE: The combined cycle units do not plan to shutdown due to high winds and are structurally rated for Category I (NYPA500) and Category II (Rav 4, AE I/II) hurricanes but may experience significant derates or plant trips during hurricane events). 5.0 WINTER STORM WARNING CRITERIA 5.1 When our subscribed weather service notifies us that a winter storm is forecasted to affect our control area, the Senior System Operator shall request the service to provide us with detailed ice and snow accumulation maps with all weather updates. 5.2 When these maps indicate that either heavy wet snow accumulations in excess of 6 inches or ice accumulation in excess of 1/2 inch are forecasted to impact our transmission corridor, the Senior System Operator shall contact a meteorologist from our subscribed weather service and/or the staff meteorologist and discuss the forecast to determine if there is a likelihood of snow and/or ice accumulating onto our transmission lines. 5.3 The Senior System Operator shall declare a Winter Storm Warning four hours prior to the storm s arrival in our control area and direct CIG to notify the various Substation & Customer Service organizations that staffing of the Major Transmission substations as noted above shall be implemented prior to the storms arrival in our control area. 5.4 Transmission facilities that are scheduled out of service and are available to be recalled should be returned to service 4-hours prior to the storm s arrival in our control area. 5.5 Initiation of the Thunderstorm Warning Contingency Cases on XA21 may be activated at the discretion of the Senior System Operator at some point during the storm, if it is determined that the snow and ice accumulations will impact the transmission corridor. 6.0 PROCEDURE 6.1 For hurricane and major coastal storms the Corporate Coastal Storm Plan will be followed. 6.2 After consulting the weather service, the Senior System Operator shall designate the Thunderstorm Warning and/or other applicable storm warnings as either Category I or Category II. The NYISO shall be responsible to initiate and terminate a Thunderstorm Warning after receiving notification from the Senior System Operator of severe Date SOP Number Supersedes Page 9 of
weather affecting or forecast to affect the Con Edison service area. The NYISO should be notified that a Category II Thunderstorm Warning not affecting the northern transmission corridor does not require solving thunderstorm contingency cases. The Senior System Operator shall also be responsible to coordinate all storm related activities at the Energy Control Center. 6.3 Per section 2.0, those major 345Kv transmission facilities that are out of service and available shall be recalled by the System Operator if they can be restored prior to the storm s arrival, and likewise, the major 345Kv transmission substations affected shall be staffed by the Substation Operations Department. 6.4 The System Operator shall request the Orange and Rockland System Operator to staff the Ladentown Substation only if O&R supervisory control is out of service. 6.5 In general, the remaining 345Kv and all 138Kv facilities that are out of service for scheduled work shall remain out of service. However, selected facilities can be recalled if it is necessary in the judgment of the Senior System Operator system or if load pocket security will be jeopardized. 6.6 Major maintenance and construction projects shall not be terminated since the equipment cannot readily be returned to service. 6.7 All live line work and in service relay testing shall continue except on the major transmission facilities, which are located in or directly supply the effected area. Reclosure equipment shall be restored for those facilities on which in service work has been terminated. 6.8 The System Operator shall activate the Thunderstorm Warning Contingency Cases on the XA21 computer as detailed in section 8.0 to allow for real time monitoring of these cases. In city generation resources may be dispatched higher based on the severity of these cases. 6.9 Once the Thunderstorm Warning has been established, the Senior System Operator and the staff meteorologist will monitor thunderstorm development. The Senior System Operator may request CIG to contact the Subscription Weather Service for thunderstorm condition updates. 6.10 The System Operator shall advise the NYISO to terminate the Thunderstorm or Hurricane Warning when storm activity no longer threatens the service territory and an "All Clear" is received from the Subscription Weather Service. Date SOP Number Supersedes Page 10 of
7.0 NOTIFICATIONS 7.1 The CIG will make corporate notifications as prescribed in CG4-9 as soon as a Thunderstorm Warning is initiated or terminated. Notifications from the Bulk Power Team will be made to the Substation Shift Manager in advance of the corporate notification from CIG. This is so the affected stations can be staffed as quickly as possible. 7.1.1 Under most circumstances, the Bulk Power Team will notify the Substation Operations Shift Manager of a Thunderstorm Warning within one hour of the storms impacting the Con Ed territory. The Substation Operations Shift Manager will then assign operating personnel to staff only the affected major 345Kv transmission substations as outlined above. CIG will use the time that the Bulk Power Team communicated to the NYISO as the Thunderstorm Warning start time as the declaration time in the corporate notification. 7.1.2 Some circumstances may dictate a notification by the Bulk Power Team to the Substation Operations Shift Manager of the declaration of an IMMEDIATE Thunderstorm Warning. An IMMEDIATE declaration will negate the one hour buffer for the operating personnel to arrive to the substations affected. All personnel (SSO, SO, TO, Substation Shift Manager, CIG) shall use the term IMMEDIATE when making notifications about and discussing the declaration with NYISO and other in-house personnel. 7.1.3 If an advance forecast for severe weather is certain requiring that stations will be staffed more than one hour in advance of severe weather, CIG will send the corporate notification using the term Advanced Thunderstorm Warning and using a declaration time provided by the Bulk Power Team. 7.2 The System Operator will notify the following as soon as a Thunderstorm Warning is initiated or terminated. The Orange and Rockland System Operator The Public Service Electric and Gas System Operator Con Ed Gas Control 7.3 The Transmission Operator will notify all District Operators as soon as a Thunderstorm Warning is initiated or terminated. Date SOP Number Supersedes Page 11 of
7.4 If during a Thunderstorm Warning it is determined that voltage reduction or load shedding will be required, the SSO will insure that the CIG notifies required agencies (as outlined in SOP CG2-11, Procedure for Notifications for Voltage Reductions). 7.5 For a Hurricane Warning CIG will make notifications as prescribed in CG4-9 as soon as a Hurricane Warning is initiated or terminated. The CIG Specialist will use Scenario #622 - Hurricane Warning/ Termination on the Communicator Notification System (CNS) to make the notifications. NOTE: If the CNS is out of service or is not operational, the CIG Information Supervisor shall make the notifications listed below immediately. The following individuals will be notified for the various classifications of hurricanes: 7.5.1 Control Room Supervisors at Indian Point (Unit #2: 914-734-5501 and Unit #3: 914-736-8277). 7.5.2 All Operators at the E.C.C. via direct lines. 7.5.3 Media Relations (460-4111, 460-6981). 7.5.4 Customer Service Electric Control Centers (#9's) (Direct Lines). 7.5.5 Facilities Management (460-6031). The CIG shall notify the individuals listed in 7.5 whenever Hurricane Warnings are issued for the mid-atlantic coastal area of the United States or as far north as New Haven, Connecticut. The mid-atlantic area extends from Virginia to New York. 8.0 OPERATING CRITERIA DURING A THUNDERSTORM WARNING 8.1 Immediately upon the initiation of a Category I, or Category II Thunderstorm Warning that affects the northern transmission corridor, the System Operator shall enable the "Thunderstorm Warning" multiple contingency cases on the XA21 Contingency Analysis program and shall monitor the "Contingency Alarm List" for the duration of the Thunderstorm Warning. If the XA21 computer is out of service, procedures as specified in SOP SO5-18 for activities of "Emergency Energy Control Center Computer System" shall be followed. 8.2 The first contingency, a single circuit loss, will be assumed to exist, such as the loss of feeders F38/Y86/W89. Date SOP Number Supersedes Page 12 of
8.3 Con Edison will operate to sustain the loss of two 345kV circuits on any single tower structure in addition to the assumed first contingency. For Example: If W93/W79 and transformer 2N at Eastview are the assumed loss; then W97 and W98 may be the next loss. 8.4 Immediately upon the institution of a Thunderstorm Warning adjustments will be made (to the extent possible without voltage reduction or load shedding) to configure the Con Edison system so that no potential Thunderstorm Warning contingency will result in a Con Edison facility exceeding its LTE (Long Time Emergency) rating. Overhead lines and inter-utility tie lines can be loaded on a postcontingency basis up to the LTE rating only. 8.5 In-city underground cables can be loaded on a post-contingency basis up to but below the STE (Short Time Emergency) rating, provided there is sufficient capability to reduce the post-contingency loading below the LTE rating within 15 minutes of the initial overload. Pre-contingency loading of all underground cables shall not exceed normal rating. 9.0 ADJUSTMENTS TO BE MADE IF THUNDERSTORM Warning POST CONTINGENCY LTE IS EXCEEDED AS DEFINED IN SECTION 8.0 9.1 Contact the NYISO and have all wheels to PJM and NEISO terminated to the extent no voltage reductions are required on those systems. 9.2 Have the NYISO bring all units to sustained rating (except any unit limited by silica). 9.3 Have the NYISO place gas turbines in service at base load. 9.4 Transfer steam load to Steam-only out Stations where possible. Reduce steam send out in Electric Stations as required to increase incity electric generation. Minimum steam pressure requirements should be maintained. 9.5 Request emergency energy from LIPA to assist in the reduction of the post contingency STE alarm. 9.6 Request the NYISO to increase loading of gas turbines to peak rating. 9.7 Disregard silica limitations on any units applicable. 9.8 Request the NYISO to bring generating stations to maximum ratings. 9.9 Terminate the NYPA to LIPA Muni wheel. Date SOP Number Supersedes Page 13 of
9.10 Terminate LIPA firm wheels to the extent no voltage reductions are required on the LIPA system. 10.0 10.0 CONTINGENCIES OCCUR, AND THE LONG TIME EMERGENCY (LTE) OR SHORT TIME EMERGENCY (STE) RATINGS ARE EXCEEDED Proceed to implement the Emergency procedures as detailed in SOP SO5-12, "Guide For Action In A Major Emergency," Paragraph 6.0. 11.0 REFERENCES 11.1 Corporate Coastal Storm Plan Revision # Revision Summary Section Modified / Added Change Detail 19 2.2 Included definitions of Normal, Low, and high density (Wet) snow 19 2.5 Included Gowanus Substation for the In-City Major 345kV Transmission Substations 19 3.3.1 Excluded retired Astoria Generating Units 19 3.4.4 Included Goethals Substation 19 3,7.2 Updated Feeder 5018 ends 18 4.6.1 ED-GO to notify Combined-Cycle Operators to report abnormal operation of Air-Cooled Condensers during Hurricanes 18 Appendix Map added showing generator locations by flood zone Date SOP Number Supersedes Page 14 of
APPENDIX A Date SOP Number Supersedes Page 15 of
APPENDIX B Pre-Season Hurricane Planning Checklist In preparation for each hurricane season, June 1 to November 30, a hurricane readiness review will be completed. This will be included in and completed as part of the annual summer preparedness initiative. This initiative will include a review of relevant System Operation and corporate procedures, and implementation of any facility related measures that need to be taken. The following procedures will be reviewed to determine if any actions or revisions are needed based on the most recent Corporate Coastal Storm Plan, and available site assessment recommendations. Corporate Coastal Storm Plan SOP SO 05-02 Thunderstorm/ Storm Procedure SOP SO 05-40 Business Continuity Plan SOP SO 05-05 Criteria for Shutting Down an Area Substation SOP SO 05-17 Load Restoration after a Station Shut-Down SOP SO 05-03 Distribution System Emergency SOP SO 05-12 Guide For Action in a System Emergency SOP SO 05-08 Storm Emergency SOP CG 04-09 CIG Notifications for Weather Events SOP ST 02-01 Declaring a Steam System Emergency 128 West End Avenue/ W65th Street Substation Emergency Response Plan B. In addition Implement any seasonal hardening requirements as determined necessary by site assessments. Review any Hurricane Planning issues with Independent Power Producers at annual meeting. Complete any annual training requirements. Review storm assignments for all personnel. Review status of emergency power. Review performance of evacuation drills. Date SOP Number Supersedes Page 16 of
APPENDIX C Generator Location by Flood Zone Date SOP Number Supersedes Page 17 of
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