Contract analysis

From: Brett Callahan <bcallahan@calderwoodharkness.com> To: William Pratt <wpratt@krd-law.com> Cc: George Trujillo <gtrujillo@calderwoodharkness.com> Subject: RE: Wetzel County Interconnect — Metering Station Design Specifications and Revised Schematics

Thank you for your continued engagement on the metering station design issues at the Wetzel County Interconnect. This email follows up on the discussions at the November 14, 2022 prehearing conference before ALJ Whitfield, as well as the subsequent informal exchanges between our respective clients' engineering teams. The purpose of this correspondence is to provide Ridgeline Natural Gas Pipeline Company's ("Ridgeline

Ridgeline proposes three (3) ultrasonic flow meter runs, each 12-inch diameter, at the Wetzel County Interconnect meter station. The meter station is located at Milepost 0.0 of the Ridgeline Pipeline System, tying into ATPC's existing 30-inch mainline at ATPC Milepost 412.6, at a receipt point in Wetzel County, West Virginia (approximate coordinates: 39.6120° N, 80.7540° W).

The three-run configuration provides both operational redundancy and measurement accuracy consistent with AGA Report No. 9 standards. I want to address directly ATPC's characterization in its protest that the metering design is "inadequate." The 12-inch meter runs are appropriately sized for the design capacity at the interconnect of 800 MMcf/d bidirectional flow, which is expandable to 1.2 Bcf/d with the addition of

Ridgeline proposes installation of dual online gas chromatographs — one primary and one backup — at the Wetzel County Interconnect. These chromatographs will provide real-time BTU content, specific gravity, and compositional analysis of gas flowing through the interconnect. Measurement will conform to AGA Report No. 8 and GPA 2261 standards. Data output from the chromatographs will feed directly into the SCADA system

These specifications are intended to address ATPC's stated concern regarding gas quality measurement at the interconnect. Dual chromatograph installations of this type are standard for interconnects of this capacity throughout the Appalachian Basin, and we believe this configuration should resolve any questions about the adequacy of gas quality monitoring.

Ridgeline's SCADA system will be integrated with ATPC's existing SCADA network at the Wetzel County Interconnect. Real-time flow data, pressure readings, gas quality data, and operational alerts will be shared between the two systems on a continuous basis. We propose a communication protocol — likely Modbus TCP/IP or an equivalent industry-standard protocol — to be mutually agreed upon by the parties' respective engi

As you may be aware, the three compressor stations on the Ridgeline system — the Wetzel Station, Mannington Station, and Waynesburg Station, representing aggregate installed compression of 45,000 HP — are already fully SCADA-integrated. The interconnect meter station would be incorporated into this existing network. The pig launcher/receiver at the interconnect will also be SCADA-monitored.

To reiterate, the proposed interconnection design capacity is 800 MMcf/d bidirectional, expandable to 1.2 Bcf/d. For context, ATPC's system capacity is 3.8 Bcf/d across its 640-mile system; the interconnect volumes therefore represent a manageable proportion of ATPC's overall throughput. The Ridgeline Pipeline System itself is a 187-mile, 24-inch-diameter high-pressure natural gas pipeline extending from the Wetzel C

The revised schematics attached hereto reflect the metering station design as currently scoped in the $22.3 million total interconnection facilities cost estimate. Ridgeline maintains its proposed cost allocation as set forth in the Draft Interconnection Agreement: $7.6 million to Ridgeline (34.1%) and $14.7 million to ATPC (65.9%). We acknowledge ATPC's advocacy for a 50/50 allocation ($11.15 million each), but I wi

- **Attachment 1:** Revised Metering Station Schematics — Wetzel County Interconnect (December 2022) — PDF engineering drawings showing the layout of the three ultrasonic flow meter runs, dual gas chromatographs, pig launcher/receiver, and SCADA interface points. - **Attachment 2:** Ultrasonic Flow Meter Technical Specifications — Summary Sheet — a one-page summary of meter manufacturer specifications, flow range, ac

The schematics incorporate modifications discussed informally between Thomas Greaves, Ridgeline's Vice President of Engineering & Operations, and ATPC's engineering team during their recent exchanges.

We would like to propose scheduling a technical call in early January 2023 between Ridgeline's engineering team, led by Mr. Greaves, and ATPC's representatives — including Sandra and ATPC's engineers — to walk through the revised schematics in detail. As you know, Ridgeline's direct testimony, including the pre-filed testimony of Thomas Greaves on engineering and system design, was filed on December 5, 2022, and prov

Ridgeline remains committed to resolving the metering design issues cooperatively in advance of the hearing schedule established by ALJ Whitfield. We believe the specifications outlined above demonstrate that the proposed metering station design is robust, industry-standard, and fully adequate for the interconnect as designed. We look forward to your and Sandra's feedback.

**Brett Callahan** Associate **Calderwood & Harkness LLP** 1601 K Street NW, Suite 900 Washington, DC 20006 Tel: (202) 555-4218 Email: bcallahan@calderwoodharkness.com

C&H Matter No. 1016-00005 FERC Docket Nos. RP22-847-000 / RP22-847-001

*CONFIDENTIALITY NOTICE: This email and any attachments are intended solely for the use of the individual(s) to whom it is addressed and may contain information that is privileged, confidential, and/or exempt from disclosure under applicable law, including but not limited to attorney-client privilege and attorney work product. This communication is made in connection with proceedings before the Federal Energy Regulat