Petal-III-FERC-Application.Pdf
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October 9, 2018 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Re: Gulf South Pipeline Company, LP Abbreviated Application for a Certificate of Public Convenience and Necessity Petal III Compression Project Docket No. CP19-___-000 Dear Ms. Bose: Gulf South Pipeline Company, LP (“Gulf South”) hereby submits for filing with the Federal Energy Regulatory Commission (“Commission”) an Abbreviated Application for a Certificate of Public Convenience and Necessity (“Application”), pursuant to Sections 7(c) of the Natural Gas Act, as amended, and Part 157.7 of the Commission’s rules and regulations. The Application requests the Commission’s authorization for Gulf South to construct, operate, and maintain two new electric-driven 5,000 horsepower compressor units, within the existing Petal III Compressor Station (“Petal III CS”) building, and a dehydration unit, thermal oxidizer, and other auxiliary, appurtenant facilities which will be all located adjacent to the Petal III CS in Forrest County, Mississippi (“Petal III Compression Project”). The proposed Petal III Compression Project will allow Gulf South to (i) increase the injection capability to 1,738 million standard cubic feet per day (“MMscf/d”); and (ii) restate the withdrawal deliverability to 2,495 MMscf/d. Pursuant to 18 C.F.R. §388.112 of the Commission's regulations, this Application consists of three volumes: Volume I - Public: Public information, including the Application and Exhibits, except for Exhibit F-1, Environmental Report and those items designated as Privileged Information or CEII; Volume I-A – Public: Public information, Exhibit F-1, Environmental Report Resource Reports 1 - 12, except for those items designated as Privileged Information or CEII; VOLUME II: PRIVILEGED Privileged information marked and labeled "CUI//PRIV” and “CONTAINS PRIVILEGED INFORMATION - DO NOT RELEASE" and includes Exhibit F-I privileged information which includes culturally sensitive resources information; and Gulf South Pipeline Company, LP 9 Greenway Plaza, Ste. 2800 Houston, TX 77046 Tel. 713.479.8000 www.gulfsouthpl.com UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) Gulf South Pipeline Company, LP ) CP19-___-000 ) ABBREVIATED APPLICATION OF GULF SOUTH PIPELINE COMPANY, LP FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY TO CONSTRUCT AND OPERATE PIPELINE FACILITIES Pursuant to Section 7(c) of the Natural Gas Act (“NGA”), 15 U.S.C. § 717f(c), and Part 157, of the regulations of the Federal Energy Regulatory Commission (“Commission” or “FERC”), 18 C.F.R. Part 157, Gulf South Pipeline Company, LP (“Gulf South”) submits this abbreviated application for a certificate of public convenience and necessity (“Application”) seeking authority for Gulf South to construct, operate, and maintain two new electric-driven 5,000 horsepower (“HP”) compressor units, within the existing Petal III Compressor Station (“Petal III Station”) building, and a dehydration unit, thermal oxidizer, and other auxiliary, appurtenant facilities which will be all located adjacent to the Petal III Station in Forrest County, Mississippi (“Petal III Compression Project” or “Project”), as more fully described in this Application. Gulf South is seeking authorization to construct the Project in order to (i) increase the injection capability to 1,738 million standard cubic feet per day (“MMscf/d”); and (ii) restate the withdrawal capability to 2,495 MMscf/d based on the operational limitations of the existing and new dehydration units. Gulf South is proposing to add these facilities to enhance operational flexibility, continue to provide reliable natural gas storage service, and potentially increase the number of injection and withdrawal cycles to satisfy the needs of new customers desiring service from the Petal Complex facilities. Subject to receiving all required authorizations and approvals, Gulf South proposes to begin construction of the Project by the third quarter of 2019 and place the Project in-service by June 2020. Based on this timing, Gulf South respectfully requests that the Commission complete its review of the Application and grant the requested authorizations in this Application on or before June 20, 2019. Gulf South will devote the resources necessary to respond promptly to any requests for additional data or information in order to permit the Commission to develop the record it needs to fulfill its statutory obligations. Receipt of an order by June 20, 2019, will allow Gulf South to meet the requirements of its customers in this area. In support of this abbreviated Application, Gulf South submits the following: I. APPLICANT The exact name of Gulf South is Gulf South Pipeline Company, LP, and its principal place of business is 9 Greenway Plaza, Suite 2800, Houston, Texas 77046. Gulf South is a wholly owned subsidiary of Boardwalk Pipelines, LP (“Boardwalk Pipelines”). Gulf South is a limited partnership organized and existing under the laws of the state of Delaware and is duly authorized to do business in the states of Texas, Louisiana, Mississippi, Alabama, and Florida. Gulf South is a natural gas company within the meaning of the NGA. It currently owns and operates approximately 7,200 miles of pipeline facilities extending from south and east Texas through Louisiana, Mississippi, southern Alabama, and western Florida. Gulf South has numerous interconnects with other interstate and intrastate pipelines and storage facilities, which allow it to serve various on-system and off-system markets. Gulf South is an open-access pipeline company that provides transportation and storage services pursuant to Part 284 of the Commission’s regulations. 2 The names, titles, and mailing addresses of the persons to whom communications and correspondence regarding this filing should be addressed are: Michael E. McMahon A. Gregory Junge Senior Vice President and General Counsel Michael R. Pincus J. Kyle Stephens Van Ness Feldman, LLP Vice President, Regulatory Affairs 1050 Thomas Jefferson St., NW Juan Eligio Jr. Seventh Floor Supervisor, Regulatory Affairs Washington, D. C. 20007 Payton Barrientos Phone: (202) 298-1800 Senior Regulatory Analyst Fax: (202) 338-2361 Gulf South Pipeline Company, LP Washington, D. C. 20007 9 Greenway Plaza, Suite 2800 [email protected] Houston, Texas 77046 [email protected] Phone: (713) 479-3480 Fax: (713) 479-1818 [email protected] [email protected] [email protected] [email protected] Each of these persons is designated to receive service in accordance with 18 C.F.R. § 385.203(b)(3). Gulf South requests the Commission to place these persons on the official service list for this proceeding pursuant to 18 C.F.R. § 385.2010. Gulf South requests that the Commission waive Rule 203(b)(3) to allow designated service to each of these persons. II. BACKGROUND The Petal Gas Storage facilities are located on the “Petal Salt Dome” in Forrest County, Mississippi. The Petal Gas Storage consists of eight caverns (Cavern Nos. 1, 3, 3-A, 6, 7, 8, 10, and 12A), including the former Hattiesburg Industrial Gas Sales, L.L.C. (“Hattiesburg”) facilities1, with a certificated total storage capacity of 46.008 billion cubic feet (“Bcf”) and a working gas 1 Petal Gas Storage, LLC acquires through merger Hattiesburg Industrial Gas Sales, LLC, 142 ¶ FERC 61,119 (2013). 3 capacity of 29.629 Bcf (“Petal Complex”). The Petal Complex includes four compressor stations providing 59,640 HP of compression (Petal 1 – 10,400 HP; Petal II – 25,000 HP, Petal III – 15,000 HP; Hattiesburg – 9,240 HP).2 By Order issued June 1, 2007, in Docket No. CP07-81-000,3 Gulf South’s predecessor Petal Gas Storage, L.L.C. (“Petal”) was authorized to construct and operate the Petal III Station and placed it in-service on December 7, 2009. While the Petal III Station was under construction, Petal filed an application and received authorization in Docket No. CP08-66-000,4 to expand its Petal III Station by adding three additional compression units totaling 15,000 HP and construct Cavern Nos. 1 and 2. The Petal III Station building was constructed with space for six compressor units; however, Petal elected not to pursue construction of the requested expansion facilities in Docket CP08-66-000 leaving space available for the three additional compressor units.5 In Docket CP14-473-000, the Commission authorized Gulf South to acquire by inter-corporate merger the Petal Complex.6 Over time Gulf South has gained operational experience and knowledge associated with operating the Petal Complex. Some customers utilizing the Petal Complex has turned its storage 2 See Petal Gas Storage Co., 64 FERC ¶ 61,190 (1993); Petal Gas Storage Co., 86 FERC ¶ 61,224 (1999), modified by, 96 FERC ¶ 61,177 (2001); Petal Gas Storage, L.L.C., 90 FERC ¶ 61,243 (2000), modified by, 96 FERC ¶ 61,177 (2001); Petal Gas Storage, L.L.C., 92 FERC ¶ 61,220 (2000); Petal Gas Storage, L.L.C., 97 FERC ¶ 61,097 (2001), amended by, 100 FERC ¶ 61,100 (2002); Petal Gas Storage, L.L.C., 102 FERC ¶ 61,243 (2003); Petal Gas Storage, L.L.C., 110 FERC ¶ 61,260 (2005); Petal Gas Storage, L.L.C., 118 FERC ¶ 61,253, reh’g granted in part and denied in part, 120 FERC ¶ 61,226 (2007); Petal Gas Storage, L.L.C., 119 FERC ¶ 61,227 (2007); Petal Gas Storage, L.L.C., 121 FERC ¶ 62,186 (2007). Effective December 9, 2008, Petal increased Cavern No. 8 capacity pursuant to Petal’s prior notice in Docket No. CP08-481-000 and its blanket certificate issued in Docket No. CP95-14-000; Petal Gas Storage, L.L.C., 132 FERC ¶ 61,168 (2010), reh’g granted, 133 FERC ¶ 61,148 (2010). Effective December 17, 2013, Petal increased Cavern 12A capacity pursuant to Petal’s prior notice in Docket No. CP14-3-000 and its blanket certificate issued in Docket No. CP95-14-000. Effective June 16, 2015, Petal increased Cavern 12A capacity pursuant to Petal’s prior notice in Docket No.