atlantic sunrise cpl south marietta extension alternative

8/10/2019 Atlantic Sunrise CPL South Marietta Extension Alternative

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Patrick Kelsey

Manheim, PA

October 23, 2014

To: Federal Energy Regulatory Commission

888 First Street, N.E.

Washington, D.C. 20426

Re: Atlantic Sunrise Project

Docket No. PF14-8

Proposing the CPL South Marietta Extension Alternative (Revision 2)

0 Changes from Previous Revision

The Columbia Gas Transmission Marietta Compressor Station was misidentified as the Texas

Eastern Marietta Compressor Station. This reference point has been relabeled throughout.

1 Introduction

Previous analysis of the Western CPL South Alternative1identified significant co-location of that route

with the existing Texas Eastern Marietta Extension2as well as the opportunity for increasing the extent

of such co-location. The Texas Eastern Marietta Extension was constructed along an existing electric

transmission line right-of-way between March and September 20113using a 100 ft wide constructionzone4that is readily identified in aerial imagery from September 2012 (see Attachment 1). Google

Street View imagery from September and October 2013 indicates that the 100 ft wide clearings created

for this project in forested areas remain devoid of trees (see Attachments 2 and 3)


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for this project in forested areas remain devoid of trees (see Attachments 2 and 3)

2 The CPL South Marietta Extension Alternative

The CPL South Marietta Extension Alternative is shown in Attachment 4, along with the corresponding

portion of the current Central Penn Line South Primary Route5. It consists of the following components,

beginning from the southern end and moving north:

1.

Interconnect with the Transco mainline adjacent to the existing Texas Eastern Marietta

Extension metering and regulating station on Johnson Road in Lower Chanceford Township, York

County

2.

Pipeline alignment paralleling the Texas Eastern Marietta Extension from the Transco mainline

interconnect to a point in Lower Windsor Township, York County just south of Yorkana Borough

3.

Deviation from the Texas Eastern Marietta Extension route in the northwest corner of Lower

Windsor Township, York County to avoid potential congestion along the existing right-of-way in

Yorkana Borough near Bluestone Road

4.

Pipeline alignment paralleling the Texas Eastern Marietta Extension from a point in Lower

Windsor Township, York County just north of Yorkana Borough to a point near Columbia Gas

Transmissions Marietta Compressor Station on Depot Road in East Donegal Township,

Lancaster County

5.

Pipeline alignment from a point near Columbia Gas Transmissions Marietta Compressor Station

in East Donegal Township, Lancaster County to the current Central Penn Line South Primary

Route near Milepost 35 at the border of Lancaster and Lebanon Counties, then continuing north

along the current Central Penn Line South Primary Route.

2 1

Transco Mainline Interconnect

The Transco mainline interconnect point for the CPL South Marietta Extension Alternative is in the

immediate vicinity of the existing Texas Eastern Marietta Extension metering and regulating station as


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2 3 Yorkana Deviation

Space constraints along the existing Texas Eastern Marietta Extension right-of-way near Bluestone Road

in Yorkana Borough may preclude adding another pipeline in this location (see Attachment 7). To

illustrate how this potential issue might be addressed, a deviation of the CPL South Marietta Extension

Alternative from the Texas Eastern Marietta Extension route was developed for this area.

This deviation departs from the Texas Eastern Marietta Extension alignment at a point in Lower Windsor

Township just south of Yorkana Borough, and continues to the west and north of Yorkana Borough,

along existing utility rights-of-way where possible, until it rejoins the Texas Eastern Marietta Extension

route (see Attachment 8).

If subsequent site analysis determines that such a deviation is not required, the overall length of the

CPL South Marietta Extension Alternative would be reduced and its total co-located length would be

increased.

2 4 Yorkana to Columbia Gas Transmissions Marietta ompressor Station

The CPL South Marietta Extension Alternative alignment from just north of Yorkana Borough to just

south of the Susquehanna River crossing parallels the existing Texas Eastern Marietta Extension. This

alignment was produced using the technique described in Section 2.2.

The CPL South Marietta Extension Alternative crosses the Susquehanna River alongside the crossing of

an existing Texas Eastern 36 inch gas pipeline. The alignment for the final 1500 ft down to the river on

the York County side, the crossing, and on to a point near the Columbia Gas Transmission Marietta

Compressor Station on the Lancaster County side follows the location of the existing Texas Eastern

pipeline (see Attachment 9).

2 5

Lancaster County

The remainder of the CPL South Marietta Extension Alternative route proceeds as directly as possible to

the Central Penn Line South Primary Route near Milepost 35 at the border of Lancaster and Lebanon

Counties From the point where it crosses PA 283 to where it joins the current Central Penn Line South


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The CPL South Marietta Extension Alternative is significantly further to the west of the Mount Joy

Wellhead Protection Area than the original Central Penn Line South Primary Route was (see Attachment

107). At the point of closest approach, the CPL South Marietta Extension Alternative is approximately5,200 ft from the Mount Joy Wellhead Protection Area, increasing to approximately 6,200 ft of

separation at the northern end and 7,100 ft of separation at the southern end. The configuration of the

CPL South Marietta Extension Alternative relative to the Mount Joy Wellhead Protection Area allows

unlimited expansion of that protection area to the north, east and south without approaching the route.

It also allows the protection area to expand to the west an additional 3,000 ft (its approximate current

width) while still maintaining a separation of over 2,000 ft.

3

Metrics

Several major characteristics measured for each route are compared in the following tables. Table 1

presents the results for the CPL South Marietta Extension Alternative as described above, using the

Yorkana deviation. Table 2 shows the changes that would occur if it turns out the Yorkana deviation is

not required. All of the measurements for the CPL South Primary Route are for the portion of that route

that would be replaced by the CPL South Marietta Extension Alternative. It should be noted that nearly

all of the forested land crossed by the CPL South Marietta Extension Alternative is already completely or

substantially cleared, whereas all of the forested land crossed by the Central Penn Line South Primary

Route would have to be cleared.

As Table 1 shows, compared to the corresponding portion of the current Central Penn Line South

Primary Route, the CPL South Marietta Extension Alternative would deliver a 21.1 mile increase in total

length co-located with existing linear utilities.

In exchange, 4.8 additional miles of pipeline would have to be constructed. Although the CPL South

Marietta Extension Alternative is longer, it interconnects with the Transco mainline sufficiently furthersouth than the Central Penn Line South Primary Route for the distance between compressor stations

(proposed Station 610 and existing Station 195) to remain essentially unchanged between the two

lt ti


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Table 1. Route Metrics if Yorkana Deviation is Used

Metric CPL South

Primary

Route

CPL South

Marietta

Extension

Alternative

Change

Length of Corresponding Segment to Transco (miles) 35.0 39.8 +4.8

Length of Corresponding Segment to Station 195 (miles) 43.6 43.8 +0.2

Length Adjacent to Interstate Pipeline ROW (miles) 0.4 25.8 +25.4

Length Adjacent to Electric Transmission Line ROW (miles) 5.3 1.0 -4.3

Total Length Co-located (miles) 5.7 26.8 +21.1

Forested Land Crossed (miles) 4.4 9.9 +5.5

Forest Interior Crossed (miles) 0.3 0 -0.3

Agricultural Land Crossed (miles) 29.5 28.2 -1.3

Karst Terrain Crossed (miles) 17.2 10.7 -6.5

Table 2. Route Metrics if Yorkana Deviation is not UsedMetric CPL South

Primary

Route

CPL South

Marietta

Extension

Change


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4 Additional Advantages

Much of the CPL South Marietta Extension Alternative could be considered a solved problem due to

the recent completion of the Texas Eastern Marietta Extension. Texas Eastern was able to build the

Marietta Extension pipeline facilities ahead of schedule and under budget8, indicating reduced execution

risk for like projects in the same area (notably, none of the forecast contingency expenses materialized).

The alignment sheets and archeological, historical, and geological survey data contained in the CP09-68

docket will no doubt be of value, potentially reducing many from-scratch efforts along this route to less

intensive reuse/augment/verify tasks.

While both routes contend with elevation changes throughout their southern extents, it is readily

apparent from Attachment 4 that the large portion of the CPL South Marietta Extension Alternative that

is co-located with the Texas Eastern Marietta Extension is characterized by long, straight pipeline

segments, whereas the corresponding portion of the Central Penn Line South Primary Route is

characterized by numerous changes in direction. It seems reasonable to anticipate that construction of

the CPL South Marietta Extension Alternative would require simpler site surveying and reduced and/or

simplified on-site pipe-forming.

5

Conclusion

The Commission encourages construction in existing rights-of-way on the basic theory that impacts,

small and large, would be minimized9. The CPL South Marietta Extension Alternative provides a

significant increase in total length co-located with existing rights-of-way in exchange for what appears to

be a minor increase in total project pipeline facilities. It seems entirely possible, indeed, probable, that

this alternative route would substantially minimize project impacts.

I ask that the Commission encourage the construction of the CPL South Marietta Extension Alternative

over the construction of the current Central Penn Line South Primary Route.

Please contact me with any questions or requests for reference material via phone at 484.437.9962 or

i il t k l @i
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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Attachment 1

Aerial imagery from September 2012 showing portion of Texas Eastern Marietta Extension construction zone near Craley Road

100 ft wide clearing created during

Marietta Extension construction

Road patch at Texas Eastern Marietta

Extension crossing Point

100 ft wide Marietta Extension

construction zone


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Attachment 2

Google Street View image from September 2013 looking north along Texas Eastern Marietta Extension from Burkholder Road


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Attachment 3

Google Street View image from October 2013 looking south along Texas Eastern Marietta Extension from Gun Club Road


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Attachment 4

CPL South Marietta Extension Alternative and corresponding portion of CPL South Primary Route

CPL South Marietta Extension

Alternative

Transco Mainline

CPL South Primary Route

To Leidy

Line

CPL South Marietta Extension Alternative CPL South Primary Route Co-location with existing linear utilities

1. Transco Mainline Interconnect

2. Paralleling Texas Eastern Marietta Extension

3. Yorkana Deviation

4. Paralleling Texas Eastern Marietta Extension

5. Lancaster County Alignment


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Attachment 5

CPL South Marietta Extension Alternative Transco mainline interconnect point

CPL South Marietta

Extension Alternative

Transco Mainline

Potential Locations for CPL South Marietta

Extension Alternative Transco Interconnect Facility

To Station 195


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Attachment 6

Example of the difference between tracking the Texas Eastern Marietta Extension alignment and the adjacent power line

Adjacent power line

CPL South Marietta



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Attachment 7

Potentially congested area near Bluestone Road in Yorkana Borough, York County

Electrical Transmission Towers

Texas Eastern

Marietta Extension

Potentially

Congested Area


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Attachment 8

CPL South Marietta Extension Alternative deviation from the Texas Eastern Marietta Extension route in Lower Windsor Township,

near Yorkana Borough, York County

Departs Texas Eastern

Marietta ExtensionAlignment Here

CPL South Marietta


Returns to Texas Eastern

Marietta Extension

Alignment Here

Texas Eastern

Marietta Extension

Potentially

Congested Area


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Attachment 9

CPL South Marietta Extension Alternative Susquehanna River crossing

Departs Texas Eastern

Alignment Here

CPL South MariettaExtension Alternative

Columbia Gas Transmission

Marietta Compressor Station

Parallels Existing 36

Texas Eastern Line

Texas Eastern Marietta Extension

Pig Launch/Recovery Facility


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Attachment 10

CPL South Marietta Extension Alternative, northern portion, including distance from Mount Joy Wellhead Protection Area

CPL South Marietta


Current Central Penn Line

South Primary Route

Same as Original Central Penn Line

South Primary Route

Mount Joy Wellhead

Protection Area

atlantic sunrise cpl south marietta extension alternative

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