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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]8/10/2019 Atlantic Sunrise CPL South Marietta Extension Alternative
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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
Extension Alternative
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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
Extension Alternative
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
Extension Alternative
Current Central Penn Line
South Primary Route
Same as Original Central Penn Line
South Primary Route
Mount Joy Wellhead
Protection Area