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20170918-5085 FERC PDF (Unofficial) 9/18/2017 11:53:01 AM

One Blue Hill Plaza, 7th Floor
Post Office Box 1565
Pearl River, NY 10965
845.620.1300 Voice | 845.620.1320 Fax

September 18, 2017

Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426

Re: Millennium Pipeline Company, L.L.C.
Eastern System Upgrade Project, Docket No. CP16-486-000
Response to September 15, 2017 Data Request

Dear Ms. Bose:

On July 29, 2016, Millennium Pipeline Company, L.L.C. (“Millennium”) filed
with the Federal Energy Regulatory Commission “Commission”) in Docket No. CP16-
486-000 an Abbreviated Application for a Certificate of Public Convenience and
Necessity (“Application”) for its proposed Eastern System Upgrade Project (“Project”).
Millennium hereby submits its responses to the Data Request issued by the Commission
Staff on September 15, 2017, in the referenced proceeding.

Description of Items Being Filed

Public:

• Response to September 15, 2017 Data Request.

Privileged and Confidential – Non-Public:

• Pipeline Hydraulic Models.

As indicated above, this filing contains non-public Privileged and Confidential
information and should be treated as confidential for use by Commission Staff only and
should not to be released to the public. Millennium is filing the additional information
pursuant to the Commission’s guidelines for eFiling.
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If you have any questions regarding this filing, please contact me at 845-620-1300.

Respectfully submitted,

/s/ Georgia Carter
Georgia Carter
Vice President and General Counsel
Millennium Pipeline Company, L.L.C.
109 North Post Oak Lane, Suite 210
Houston, TX 77024

Attachments

cc: Darya Khanin, FERC
Joseph Caramanica, FERC
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Request:

As part of its response to environmental alternatives filed on May 16, 2017, Millennium states
that the Wagoner alternative that was considered during the Minisink Compressor Station Project
is not a viable or reasonable alternative to the Eastern System Upgrade Project. Millennium
further states that from a system design and hydraulic standpoint, the Wagoner alternative would
be sited too close to the existing Minisink Compressor Station and would create operational
deficiencies in Millennium’s system.

Demonstrate the hydraulic deficiencies, as described in the May 16, 2017 filing, and support
Millennium’s response by providing hydraulic models of its pipeline system used to reject the
Wagoner alternative.

Response:

Millennium explained in its May 16, 2017 Answer to Comments on the Environmental
Assessment, “the Wagoner alternative is not an alternative to the [Eastern System Upgrade
(“ESU”)] Project because, from a system design and hydraulics standpoint, it would be sited too
close to the existing Minisink Compressor Station and would create operational deficiencies in
Millennium’s system.”

Like all natural gas pipeline systems, the pressure of Millennium’s system needs to be as high as
practicable in order to use the pipeline facilities most efficiently. Compressor stations are
located along the pipeline route to maintain sufficient pressures and flows. Compressor stations
spaced too far apart from each other cannot maintain optimal compression and flow because of
the drops in pressure between the stations. While compressor stations spaced too closely
together negatively interact with each other and cause hydraulic and operational issues.

As part of the ESU Project, Millennium proposes to construct a new Highland Compressor
Station and add compression to the existing Hancock Compressor Station to allow for additional
flow capacity. See Hydraulic Model No. 1. The pipeline distance between the existing Hancock
Compressor Station and existing Minisink Compressor Station is about 52.3 miles. The new
Highland Compressor Station would be located approximately halfway between the existing
Hancock and Minisink Compressor Stations, i.e., the new Highland Compressor Station would
be located 24.2 miles from the Hancock Compressor Station and 28.1 from the Minisink
Compressor Station. The approximate mid-point location of the Highland Compressor Station
was chosen because the friction between the flow of the gas and the interior wall of the pipe, as
well as elevation differences along the pipeline path between the Hancock Compressor Station
and the proposed location of the Highland Compressor Station, would otherwise slow down the
gas and work to reduce the pressure in the pipeline. The location of the proposed Highland
Compressor Station prevents system pressure from getting too low, which in turn facilitates the
flow necessary for the ESU Project.

The Wagoner Alternative was considered as an alternative to constructing the Minisink
Compressor Station in Docket No. CP11-515. The Wagoner Alternative would have involved
adding a new compressor station at Millennium’s existing Wagoner Meter Station and adding
pipeline looping facilities. The Minisink Compressor Station is now part of Millennium’s
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system, which means that Millennium is not seeking additional compression as a “substitute” for
the Minisink Compressor Station as part of the ESU Project. Instead, Millennium is seeking to
address the drop in pressure that would otherwise occur between the existing Minisink and
Hancock Compressor Stations in the ESU Project. For this reason, the Wagoner Alternative was
not considered to be an alternative as part of the ESU Project.

Notably, hydraulic issues would arise if Millennium did not construct the proposed Highland
Compressor Station, but instead added a new compressor station at the existing Wagoner Meter
Station as part of a so-called Wagoner Alternative to the ESU Project. The Wagoner Meter
Station is not located in a hydraulically favorable location to meet the purpose of the ESU
Project. The Wagoner Compressor Station would be located 41.8 miles from the Hancock
Compressor Station and only 10.5 miles from the Minisink Compressor Station. This location is
too far from the Hancock Compressor Station to support the additional flows because of the
substantial pressure drop over the 41.8 miles between the two compressor stations. See
Hydraulic Model No. 2.

Moving the compression from the proposed location of the Highland Compressor Station to the
Wagoner Meter Station as part of the Wagoner Alternative would result in a reduction in
capacity of the Project. This reduction in capacity caused by moving the location of the
compression would be approximately 37,000 dekatherms per day (Dth/d). Therefore, the total
Project capacity under this alternative would only be 186,000 Dth/d, which is not sufficient to
provide the additional 223,000 Dth/d system flows necessary for the ESU Project. Even
installing additional horsepower above and beyond the unit capacity proposed at the Highland
Compressor Station at the Wagoner Meter Station as part of the Wagoner Alternative, would
only decrease the deficit in capacity to approximately 30,000 Dth/d, which would also not be
sufficient to meet objectives of the ESU Project. See Hydraulic Model No. 3. In addition, the
models also indicate that suction pressures at the Minisink Compressor Station would be too high
if the compression proposed at the Highland Compressor Station was moved to the Wagoner
Meter Station due to the close physical proximity of the Highland Compressor Station and the
Wagoner Meter Station, under the Wagoner Alternative.

Millennium has provided the requested pipeline hydraulic models, as noted above, filed
electronically under a separate cover as “Privileged and Confidential.”

Respondent: Patrick Riban
Title: Manager of System Design and Construction
Phone: 845-620-1300
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CERTIFICATE OF SERVICE

Pursuant to Rule 2010 of the Commission’s Rules of Practice and Procedure, 18

C.F.R. § 385.2010 (2017), I hereby certify that I have this day served the foregoing

document upon each person designated on the official service list compiled by the

Secretary in this proceeding.

Dated at Washington, D.C., this 18th day of September, 2017.

/s/ Marco Bracamonte
Marco A. Bracamonte
Paralegal
Van Ness Feldman, LLP
1050 Thomas Jefferson St., N.W.
Seventh Floor
Washington, D.C. 20007-3877
(202) 298-1800
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Document Content(s)

Response to Sep. 15, 2017 Data Request 091817.PDF.....................1-6