UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Ridgeline Midstream Services LLC
Docket No. RP22-847-000 Docket No. RP22-847-001
PRE-FILED DIRECT TESTIMONY OF THOMAS GREAVES
ON BEHALF OF RIDGELINE MIDSTREAM SERVICES LLC
ENGINEERING AND SYSTEM DESIGN OF THE RIDGELINE PIPELINE SYSTEM; PROPOSED INTERCONNECTION FACILITIES AT THE WETZEL COUNTY INTERCONNECT
Filed: December 5, 2022
COUNSEL FOR RIDGELINE MIDSTREAM SERVICES LLC:
Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006
George Trujillo, Responsible Partner Brett Callahan, Lead Associate David Stanton, Working Associate
TABLE OF CONTENTS
I. INTRODUCTION AND QUALIFICATIONS
Q. Please state your full name, title, and business address.
A. My name is Thomas Greaves. I am the Vice President of Engineering and Operations of Ridgeline Midstream Services LLC. My business address is 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301.
Q. On whose behalf are you submitting this testimony?
A. I am submitting this pre-filed direct testimony on behalf of Ridgeline Midstream Services LLC ("Ridgeline" or "RMS"), a Delaware limited liability company and the applicant in these proceedings. Ridgeline is a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company. Ridgeline is the owner and operator of the Ridgeline Pipeline System, an interstate natural gas transportation pipeline located in the Appalachian Basin. Ridgeline is the applicant in both the rate case proceeding, Docket No. RP22-847-000, and the interconnection authorization proceeding, Docket No. RP22-847-001.
Q. Please describe your professional background and qualifications.
A. I have over twenty-five years of professional experience in midstream natural gas pipeline engineering, design, construction, and operations. I received a Bachelor of Science degree in Mechanical Engineering from West Virginia University in 1995 and a Master of Science degree in Petroleum Engineering from the University of Pittsburgh in 1998. I am a Registered Professional Engineer licensed in the states of West Virginia (License No. PE-14872) and Pennsylvania (License No. PE-062814).
I began my career in 1997 as a pipeline design engineer with Allegheny Transmission Company, where I was responsible for the engineering design and analysis of natural gas transmission pipeline facilities in the Appalachian region. During my tenure at Allegheny Transmission, I gained extensive experience in pipeline hydraulic modeling, route selection, materials specification, and compliance with applicable Department of Transportation ("DOT") and Pipeline and Hazardous Materials Safety Administration ("PHMSA") regulations under 49 C.F.R. Part 192.
In 2002, I joined Mountain State Pipeline Services, Inc. as a Senior Project Engineer, where I managed the engineering and construction of several midstream natural gas pipeline projects in West Virginia and Pennsylvania, including a 64-mile, 20-inch-diameter gathering system and associated compression facilities. I was promoted to Director of Engineering in 2006 and was responsible for overseeing all engineering and construction activities across Mountain State's portfolio of midstream assets.
From 2008 to 2012, I served as Vice President of Engineering at Pinnacle Midstream LLC, a midstream natural gas company operating in the Marcellus Shale play. At Pinnacle Midstream, I directed the design, permitting, and construction of approximately 280 miles of high-pressure gathering and transmission pipeline, as well as six compressor stations with an aggregate installed compression of over 90,000 horsepower. My responsibilities at Pinnacle Midstream also encompassed SCADA system design and implementation, pipeline integrity management, and environmental compliance.
In 2013, I was retained by Dunmore Energy Holdings Ltd. to lead the development of the Ridgeline Pipeline System from the initial conceptual engineering phase. I have served as Vice President of Engineering and Operations at Ridgeline Midstream Services LLC since the formation of the company in 2014. In that capacity, I have been responsible for all engineering, construction, operations, and maintenance activities for the Ridgeline Pipeline System from its inception through the present day. I oversaw the design, permitting, and construction of the 187-mile Ridgeline Pipeline System from initial groundbreaking in early 2020 through the October 1, 2021 in-service date. I currently oversee the day-to-day operations of the system, including pipeline integrity management, compression operations, metering, SCADA, and environmental compliance.
Throughout my career, I have been responsible for the engineering design and construction management of natural gas pipeline facilities with an aggregate investment value exceeding $2 billion. I am a member of the American Society of Mechanical Engineers ("ASME"), the Society of Petroleum Engineers ("SPE"), and the Southern Gas Association ("SGA"). I have authored or co-authored technical papers on pipeline design, compression optimization, and ultrasonic flow measurement published in the Brightmoor Software and presented at the American Gas Association ("AGA") Operations Conference.
Q. Have you previously submitted testimony before the Federal Energy Regulatory Commission or any state regulatory body?
A. Yes. I submitted pre-filed direct testimony before the Public Service Commission of West Virginia in Case No. 18-0742-G-PC regarding compression facilities associated with a gathering pipeline system in Doddridge County, West Virginia. I have not previously submitted testimony before the Federal Energy Regulatory Commission.
Q. What is the purpose of your testimony?
A. The purpose of my testimony is fourfold. First, I provide a comprehensive engineering and operational description of the Ridgeline Pipeline System, including its design parameters, physical characteristics, capacity, and operating capabilities. Second, I describe the system's current throughput and utilization and explain the engineering basis for the ramp-up trajectory that Ridgeline's throughput is following. Third, I describe in detail the proposed interconnection facilities at the Wetzel County Interconnect, where the Ridgeline Pipeline System would physically interconnect with the pipeline system of Appalachian Trunk Pipeline Company, LLC ("ATPC"), including the design of the proposed metering station, pig launcher/receiver facilities, and associated infrastructure. Fourth, I respond to the protest filed by ATPC on August 15, 2022, which challenges the adequacy of Ridgeline's proposed metering station design and the proposed cost allocation for the interconnection facilities.
My testimony is intended to provide the Commission with the engineering and technical foundation necessary to evaluate both the rate case filing in Docket No. RP22-847-000 and the interconnection authorization application in Docket No. RP22-847-001. On matters of cost-of-service, rate design, and legal analysis, I defer to the testimony of Ridgeline's other witnesses, specifically Angela Moretti (Vice President, Finance and Regulatory Affairs) and Dr. Natasha Orlov (outside counsel, regulatory and policy matters).
Q. Please identify the exhibits attached to or referenced by your testimony.
A. The following exhibits are attached to or referenced by my testimony:
Each of these exhibits was prepared under my direction and supervision by Ridgeline's engineering staff, and I have reviewed each exhibit for accuracy and completeness. I am familiar with the contents of each exhibit and am prepared to discuss them in detail.
II. OVERVIEW OF THE RIDGELINE PIPELINE SYSTEM
Q. Please provide a general overview of the Ridgeline Pipeline System.
A. The Ridgeline Pipeline System is a high-pressure interstate natural gas transportation pipeline located in the Appalachian Basin, traversing portions of Wetzel County, West Virginia, and Greene County, Pennsylvania, as well as intermediate counties in West Virginia. The system was designed, engineered, and constructed under my direct supervision and was placed in service on October 1, 2021. The total original construction cost of the Ridgeline Pipeline System was $587.2 million. The system was designed to provide firm transportation service for natural gas produced from the prolific Marcellus and Utica shale formations in the Appalachian Basin, delivering gas from upstream production areas in West Virginia to downstream market hubs and interconnections in southwestern Pennsylvania.
The Ridgeline Pipeline System is depicted on the system map attached as Exhibit TG-1, which shows the pipeline route from the receipt point at the Wetzel County Interconnect in Wetzel County, West Virginia, to the delivery point at the Waynesburg Compressor Station in Greene County, Pennsylvania. The exhibit also identifies the locations of the three compressor stations, mainline valve stations, and other key facilities along the route.
Q. Please describe the principal physical characteristics of the pipeline.
A. The principal physical characteristics of the Ridgeline Pipeline System are as follows:
Pipeline Length: The total pipeline length is 187 miles, measured from the receipt point at the Wetzel County Interconnect (Milepost 0.0) to the delivery point at the Waynesburg Compressor Station (Milepost 187.0). The pipeline follows a generally northeast route through the Appalachian terrain of northern West Virginia and into southwestern Pennsylvania.
Diameter: The pipeline is constructed of 24-inch outside diameter steel pipe throughout its entire 187-mile length. The 24-inch diameter was selected based on hydraulic analysis to provide optimal flow characteristics and capacity for the projected throughput volumes while maintaining reasonable operating pressures and compression requirements.
Material: The pipeline is constructed of API 5L X-70 line pipe, which is a high-strength carbon steel pipe manufactured in accordance with the American Petroleum Institute's Specification 5L for Line Pipe. The X-70 designation indicates a minimum specified yield strength of 70,000 pounds per square inch (psi). The pipe is externally coated with three-layer fusion-bonded epoxy ("FBE") for corrosion protection and is internally coated with a proprietary drag reduction coating to reduce friction losses and improve flow efficiency. Wall thickness varies along the route based on class location designations and design factors established under DOT/PHMSA regulations at 49 C.F.R. Part 192, but the predominant wall thickness is 0.375 inches for Class 1 design areas and 0.469 inches for Class 2 design areas.
Maximum Allowable Operating Pressure (MAOP): The MAOP of the Ridgeline Pipeline System is 1,440 pounds per square inch gauge (psig) in Class 1 design areas and 1,200 psig in Class 2 design areas, consistent with the design factor requirements of 49 C.F.R. § 192.111 and the pipe specifications noted above. All pipeline segments have been hydrostatically tested in accordance with 49 C.F.R. Part 192, Subpart J, to a minimum test pressure of 1.25 times the MAOP for Class 1 areas and 1.25 times the MAOP for Class 2 areas, as applicable.
Design Capacity: The system's design capacity is 1.2 billion cubic feet per day ("Bcf/d"), which is equivalent to 1,200,000 dekatherms per day ("Dth/d") at an assumed average heating value of 1,000 British Thermal Units ("BTU") per standard cubic foot. The design capacity was established through comprehensive hydraulic modeling of the 187-mile system, taking into account pipe diameter, pipe roughness, elevation changes along the route, operating pressures, compression configurations, and ambient temperature conditions. The results of the hydraulic modeling are presented in Exhibit TG-7.
Right-of-Way: The pipeline is installed within a permanent easement with a typical width of 50 feet through predominantly rural terrain in the Appalachian region. In certain locations, the permanent easement width was expanded to accommodate side slopes, drainage features, or proximity to other utilities. During construction, a temporary construction right-of-way of up to 100 feet total width was utilized, which has since been restored to its original contours and revegetated in accordance with the approved erosion and sediment control plan.
Q. Please describe the receipt and delivery points of the system.
A. The Ridgeline Pipeline System has one principal receipt point and one principal delivery point, as described below:
Receipt Point — Wetzel County Interconnect: The primary receipt point of the Ridgeline Pipeline System is the Wetzel County Interconnect, located in Wetzel County, West Virginia, at approximate geographic coordinates 39.6120° North latitude, 80.7540° West longitude. This is designated as Milepost 0.0 of the Ridgeline Pipeline System. The Wetzel County Interconnect is the location at which natural gas will be received from ATPC's existing 30-inch mainline at ATPC Milepost 412.6, as well as from upstream gathering systems operated by third-party producers in the Marcellus and Utica shale formations. The proposed physical interconnection with ATPC at this location is the subject of the interconnection authorization proceeding in Docket No. RP22-847-001, and I describe the proposed interconnection facilities in detail in Section VI of this testimony. In addition to the proposed ATPC interconnection, the Wetzel County Interconnect includes existing receipt point metering and piping facilities that enable the receipt of gas from two upstream gathering systems that currently deliver gas into the Ridgeline Pipeline System.
Delivery Point — Waynesburg Compressor Station: The delivery point of the Ridgeline Pipeline System is the Waynesburg Compressor Station, located in Greene County, Pennsylvania, at approximate geographic coordinates 39.8965° North latitude, 80.1810° West longitude. This is designated as Milepost 187.0 of the Ridgeline Pipeline System and serves as the terminus of the system. At the Waynesburg Compressor Station, gas is delivered into downstream markets through existing interconnections with two regional pipeline systems. The Waynesburg Compressor Station also provides terminal compression for delivery into these downstream interconnections at required delivery pressures.
The system map attached as Exhibit TG-1 depicts both the receipt point and the delivery point, along with the pipeline route and key facilities between them.
III. COMPRESSOR STATIONS
Q. Please describe the compressor stations on the Ridgeline Pipeline System.
A. The Ridgeline Pipeline System includes three compressor stations with an aggregate installed compression of 45,000 horsepower ("HP"). Each station was designed and constructed under my supervision and was placed in service concurrently with the pipeline on October 1, 2021. The three stations are strategically located along the 187-mile pipeline route to optimize pressure profiles, maximize throughput capacity, and minimize fuel gas consumption. The locations and specifications of all three compressor stations are detailed in Exhibit TG-2. I describe each station below:
1. Wetzel Station. The Wetzel Station is located near the receipt point at the Wetzel County Interconnect in Wetzel County, West Virginia, at approximately Milepost 2.5 of the Ridgeline Pipeline System. This station provides initial compression for gas entering the system, boosting receipt-point pressure to the operating pressure required for efficient long-distance transmission through the 24-inch pipeline. The Wetzel Station has an installed compression capacity of 15,000 HP, consisting of three Northgate Enterprises Taurus 60 gas-fired centrifugal compressor units, each rated at 5,000 HP. Two of the three units are required for normal operations at design throughput, with the third unit serving as a standby for redundancy and maintenance purposes (N+1 configuration). Each compressor unit is equipped with dry low-emissions ("DLE") combustion technology to minimize nitrogen oxide ("NOx") emissions, as well as oxidation catalysts for carbon monoxide ("CO") reduction. The station also includes inlet gas cooling, dehydration, and filtration/separation equipment for gas conditioning prior to compression.
2. Mannington Station. The Mannington Station is located at an intermediate point along the pipeline route, approximately at the midpoint of the 187-mile system, at approximately Milepost 94.0, in Marion County, West Virginia. The Mannington Station provides mainline boost compression to maintain operating pressure and flow rates across the Appalachian terrain, compensating for friction losses and elevation changes encountered along the pipeline route between the Wetzel Station and the Waynesburg Station. The Mannington Station has an installed compression capacity of 15,000 HP, also consisting of three Northgate Enterprises Taurus 60 gas-fired centrifugal compressor units, each rated at 5,000 HP, in an N+1 configuration identical to the Wetzel Station. Emission control equipment at the Mannington Station mirrors that installed at the Wetzel Station, including DLE combustion technology and oxidation catalysts.
3. Waynesburg Station. The Waynesburg Station is located at the delivery point of the Ridgeline Pipeline System in Greene County, Pennsylvania, at Milepost 187.0. The Waynesburg Station serves as the terminal compressor station, providing final compression for delivery of gas into downstream pipeline interconnections at the required delivery pressures specified in the applicable transportation agreements. The Waynesburg Station has an installed compression capacity of 15,000 HP, consisting of two Granite Harbor Group G3616 gas-fired reciprocating compressor units, each rated at 7,500 HP. One unit is required for normal operations at design throughput, with the second unit serving as a standby (N+1 configuration). The reciprocating compressor units at the Waynesburg Station were selected for their operational flexibility and ability to efficiently handle variable throughput volumes and discharge pressure requirements associated with downstream deliveries. Emission control equipment includes lean-burn engine technology and selective catalytic reduction ("SCR") systems for NOx control.
All three compressor stations are equipped with modern Supervisory Control and Data Acquisition ("SCADA") systems for remote monitoring and control from Ridgeline's operations center in Charleston, West Virginia. The SCADA systems at each station monitor and record key operating parameters, including suction and discharge pressures, temperatures, gas flow rates, compressor unit operating status, vibration levels, and emission monitoring data. Each station is also equipped with emergency shutdown ("ESD") systems that can be activated remotely from the operations center or locally at the station in the event of an abnormal operating condition. All three stations comply with applicable air quality permits issued by the West Virginia Department of Environmental Protection (for the Wetzel and Mannington stations) and the Pennsylvania Department of Environmental Protection (for the Waynesburg Station).
Q. What is the role of compression in achieving the system's design capacity?
A. The 45,000 HP of aggregate compression installed across the three compressor stations is essential to achieving the system's design capacity of 1.2 Bcf/d (1,200,000 Dth/d) over the 187-mile route. The Ridgeline Pipeline System traverses terrain with significant elevation changes and distance between the receipt and delivery points. Without adequate compression, frictional pressure losses and elevation-related pressure differentials would reduce the pipeline's ability to transport gas at the design volume.
Comprehensive hydraulic modeling of the Ridgeline Pipeline System, the results of which are presented in Exhibit TG-7, demonstrates that the three-station compression configuration — with 15,000 HP at each of the Wetzel, Mannington, and Waynesburg stations — optimizes the pressure profile along the 187-mile route. Specifically, the hydraulic model shows that the three-station configuration maintains pipeline operating pressures within the MAOP at all points along the system while minimizing line pack losses and fuel gas consumption. The model confirms that the system can transport the full design volume of 1.2 Bcf/d under normal operating conditions, including at varying ambient temperature conditions ranging from winter lows to summer highs that affect compressor efficiency and gas density.
The selection of three compressor stations, rather than two or four, was the product of an optimization analysis conducted during the preliminary engineering phase of the project. That analysis evaluated multiple compression configurations and station locations to identify the configuration that would achieve the design capacity at the lowest lifecycle cost, taking into account capital costs, fuel gas consumption, maintenance requirements, and operational flexibility. The three-station configuration was determined to be the optimal solution, providing the most efficient use of compression horsepower while maintaining adequate pressure margins for reliable operations.
IV. CURRENT THROUGHPUT AND UTILIZATION
Q. What is the current throughput on the Ridgeline Pipeline System?
A. As of the test year ended March 31, 2022, the Ridgeline Pipeline System's current throughput is approximately 680 million cubic feet per day ("MMcf/d"), which is equivalent to approximately 680,000 Dth/d at the assumed average heating value of 1,000 BTU per standard cubic foot. This throughput level represents a utilization rate of approximately 56.67% of the system's design capacity of 1,200,000 Dth/d, calculated as follows: 680,000 Dth/d divided by 1,200,000 Dth/d equals 56.67%. Current throughput and utilization data are presented in detail in Exhibit TG-8, which provides monthly throughput volumes for the period from October 2021 (the in-service date) through March 2022 (the end of the test year).
Q. Why is current throughput below design capacity?
A. The current throughput of approximately 680 MMcf/d, representing approximately 56.67% utilization of the system's design capacity, reflects the early stage of operations of the Ridgeline Pipeline System rather than any engineering or design limitation. The system was placed in service on October 1, 2021, and the test year ended March 31, 2022, encompasses only the first six months of commercial operations. Several factors contribute to the current throughput level being below design capacity:
First, throughput on the Ridgeline Pipeline System is ramping up as additional shippers execute firm and interruptible transportation agreements. At the time the system was placed in service, Ridgeline had executed firm transportation agreements for approximately 500,000 Dth/d of capacity. Since that time, additional agreements have been executed, and the current contracted capacity supports the observed throughput of approximately 680,000 Dth/d. Ridgeline is actively marketing the remaining available capacity on the system to prospective shippers, and the trajectory of contracted volumes is consistent with achieving full subscription of the system's design capacity within the timeframe projected in Ridgeline's initial rate case filing.
Second, upstream production in the Marcellus and Utica shale formations in the Ridgeline Pipeline System's market area is expanding, and additional production volumes are expected to come online as new wells are drilled and completed and as additional gathering infrastructure is constructed by upstream gathering operators to connect producing wells to the Ridgeline receipt point at the Wetzel County Interconnect.
Third, and most significantly, the proposed physical interconnection with ATPC at the Wetzel County Interconnect — which is the subject of the interconnection authorization proceeding in Docket No. RP22-847-001 — remains pending. Completion of the ATPC interconnection is expected to provide significant additional supply access to the Ridgeline Pipeline System by enabling the receipt of gas from ATPC's 30-inch mainline, which transports gas from numerous producing areas throughout the Appalachian Basin. The interconnection authorization sought in Docket No. RP22-847-001 is a prerequisite to the construction of the interconnection facilities, and the delay in obtaining that authorization has correspondingly delayed the expected throughput ramp-up.
The Ridgeline Pipeline System was designed and engineered to accommodate the full 1.2 Bcf/d design capacity, and as I discuss in greater detail in Section VIII of this testimony, the hydraulic modeling results (Exhibit TG-7) confirm that the system is fully capable of transporting at that capacity. Current throughput levels are expected to increase materially as the proposed interconnection with ATPC is completed and as additional shipper agreements are executed and additional market access is secured.
V. PIPELINE CONSTRUCTION AND ENGINEERING SPECIFICATIONS
Q. Please describe the construction of the Ridgeline Pipeline System.
A. The construction of the Ridgeline Pipeline System was a major infrastructure project that I directed from the initial engineering phase through the in-service date. Construction commenced in early 2020, following the completion of all necessary permitting and regulatory approvals, and was completed in September 2021. The system was placed in service on October 1, 2021. The total original construction cost was $587.2 million, as reflected on Ridgeline's books and records and as verified by the independent appraisal firm of Ridgepoint Appraisal & Valuation Inc. of Houston, Texas.
The construction scope encompassed the following principal elements:
Pipeline Installation: Installation of 187 miles of 24-inch-diameter API 5L X-70 steel pipe, including clearing and grading of the right-of-way, trenching, pipe stringing, welding, coating inspection and repair, lowering-in, backfilling, and restoration. The pipeline was installed at a minimum depth of cover of 36 inches in Class 1 locations and 36 inches in Class 2 locations, in accordance with 49 C.F.R. § 192.327. All field welds were performed by qualified welders in accordance with API 1104 and were subjected to 100% non-destructive examination using radiographic and/or ultrasonic testing methods.
Compressor Station Construction: Construction of three compressor stations (Wetzel, Mannington, and Waynesburg) with an aggregate installed compression of 45,000 HP, as described in Section III of this testimony. Compressor station construction included site preparation, foundations, compressor unit installation, piping and valving, electrical and instrumentation systems, emission control equipment, control buildings, and associated infrastructure.
Mainline Valve Stations: Installation of numerous mainline block valve stations along the 187-mile route, spaced in accordance with the requirements of 49 C.F.R. § 192.179 for Class 1 and Class 2 locations. Each mainline valve station includes remotely operable mainline block valves with actuators controlled through the SCADA system, as well as manual bypass valves and blowdown valves.
Cathodic Protection System: Installation of a comprehensive cathodic protection system for external corrosion control on all buried steel pipe, including impressed current cathodic protection stations, sacrificial anode beds, test stations, and associated wiring. The cathodic protection system was designed and installed in accordance with NACE International standards and 49 C.F.R. § 192.455 et seq.
Fiber Optic Cable: Installation of fiber optic communications cable in the pipeline trench for SCADA data transmission between the operations center in Charleston, West Virginia, the three compressor stations, and key valve and metering sites along the pipeline route. The fiber optic system provides high-speed, reliable communication for real-time monitoring and control of all pipeline facilities.
Associated Appurtenances: Construction of associated pipeline appurtenances, including launchers and receivers for in-line inspection tools, pressure and temperature instrumentation, gas sampling and analysis equipment, pipeline markers, and right-of-way access roads.
The pipeline route traverses varied terrain characteristic of the Appalachian region, including river and stream crossings, road and highway crossings, utility crossings, forested areas, agricultural land, and mountainous topography with significant elevation changes. Major waterbody crossings were accomplished using horizontal directional drilling ("HDD") to minimize environmental disturbance to streams and wetlands. Road crossings, including crossings of state highways and county roads, were performed using conventional bore methods to avoid disruption to traffic. All crossings were performed in accordance with applicable permits issued by the West Virginia Department of Environmental Protection, the Pennsylvania Department of Environmental Protection, the U.S. Army Corps of Engineers, and other relevant federal and state agencies.
All construction activities were performed in accordance with the pipeline safety regulations of the DOT and PHMSA at 49 C.F.R. Part 192, applicable state regulations in West Virginia and Pennsylvania, and FERC requirements. Ridgeline retained an independent third-party inspection firm to provide full-time construction inspection and quality assurance services throughout the construction period, and I personally conducted regular site visits and inspections during construction.
Q. Please describe the pipeline integrity and safety systems.
A. The Ridgeline Pipeline System was designed with comprehensive integrity and safety systems to ensure the safe and reliable transportation of natural gas throughout the system's operating life. These systems include the following:
In-Line Inspection Capability: The pipeline was designed and constructed to be fully compatible with in-line inspection ("ILI") tools, commonly known as "smart pigs." ILI capability was built into the pipeline design from the outset, with pig launcher facilities at the Wetzel County Interconnect (Milepost 0.0) and pig receiver facilities at the Waynesburg Station (Milepost 187.0). The pipeline includes full-opening mainline block valves at all valve stations to accommodate passage of ILI tools, and the pipeline geometry (bends, fittings, and valves) was designed to ensure unrestricted passage of modern multi-diameter ILI tools. Ridgeline has conducted an initial baseline ILI run using a combination magnetic flux leakage ("MFL") and caliper tool, and the results confirmed that the pipeline is in excellent condition with no reportable anomalies.
Mainline Block Valves: Mainline block valves are spaced along the pipeline route in accordance with the requirements of 49 C.F.R. § 192.179, which specifies maximum valve spacing based on class location designations. In Class 1 locations, mainline valves are spaced at intervals not exceeding 20 miles, and in Class 2 locations, valves are spaced at intervals not exceeding 15 miles. Each mainline valve is equipped with a pneumatic or electric actuator for remote operation via the SCADA system, as well as a manual override for local operation.
Cathodic Protection System: As noted above, a comprehensive cathodic protection system has been installed for external corrosion control on all buried steel pipe. The system is designed to maintain a pipe-to-soil potential of at least negative 850 millivolts (with reference to a copper/copper sulfate reference electrode) in accordance with NACE International Standard Practice SP0169 and 49 C.F.R. § 192.455 et seq. Cathodic protection readings are monitored at test stations along the pipeline route and are reviewed and analyzed on a regular basis.
SCADA System: The SCADA system provides continuous, real-time monitoring and control of all pipeline facilities from Ridgeline's operations center in Charleston, West Virginia. The SCADA system monitors and records key operating parameters at all compressor stations, mainline valve stations, and metering facilities, including pressures, temperatures, flow rates, compressor unit status, and gas quality data. The SCADA system includes alarm management capabilities that notify operations personnel of abnormal conditions, and it enables remote operation of mainline valves, compressor units, and emergency shutdown systems.
Emergency Shutdown Systems: Emergency shutdown ("ESD") systems are installed at all three compressor stations and at the Wetzel County Interconnect metering facilities. ESD systems can be activated remotely from the operations center via the SCADA system, or locally at each facility. Activation of an ESD system initiates an automatic shutdown of compressor units, closure of mainline isolation valves, and blowdown of station piping to safely depressurize affected facilities.
Pipeline Integrity Management Plan: Ridgeline has developed and implemented a comprehensive pipeline integrity management plan ("IMP") in accordance with the requirements of 49 C.F.R. Part 192, Subpart O. The IMP addresses the identification, assessment, and mitigation of threats to pipeline integrity, including external corrosion, internal corrosion, stress corrosion cracking, manufacturing defects, construction defects, equipment failures, third-party damage, and natural force damage. The IMP specifies the use of ILI, direct assessment, pressure testing, and other integrity assessment methods at intervals consistent with regulatory requirements and industry best practices.
VI. PROPOSED INTERCONNECTION FACILITIES AT THE WETZEL COUNTY INTERCONNECT
Q. Please describe the proposed interconnection with ATPC.
A. Ridgeline seeks authorization under Docket No. RP22-847-001 for the construction and operation of physical interconnection facilities to enable the interconnection of the Ridgeline Pipeline System with the existing pipeline network of Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect. The proposed interconnection would tie into ATPC's existing 30-inch-diameter mainline at ATPC Milepost 412.6, which is collocated with Milepost 0.0 of the Ridgeline Pipeline System in Wetzel County, West Virginia. The proposed interconnection would enable the bidirectional flow of natural gas between the ATPC and Ridgeline systems, providing mutual benefits to shippers on both systems by enhancing market access, supply diversity, and transportation flexibility.
The Wetzel County Interconnect site was selected during the initial design phase of the Ridgeline Pipeline System based on several engineering and commercial factors, including: (i) the proximity of ATPC's 30-inch mainline to the planned receipt point of the Ridgeline system; (ii) the favorable terrain and soil conditions at the site for construction of the interconnection facilities; (iii) the availability of adequate land area for the meter station, pig launcher/receiver, control building, and associated infrastructure; and (iv) the accessibility of the site for construction equipment and ongoing operations and maintenance activities. The site has been surveyed, and geotechnical investigations have been completed confirming the suitability of subsurface conditions for the proposed facilities.
Q. What is the design capacity of the proposed interconnection?
A. The proposed interconnection is designed with an initial bidirectional capacity of 800 MMcf/d (800,000 Dth/d). This initial capacity was selected to accommodate the near-term transportation needs of shippers on both the Ridgeline and ATPC systems while providing for future expansion. The interconnection design is expandable to a maximum capacity of 1.2 Bcf/d (1,200,000 Dth/d), matching Ridgeline's full system design capacity, through the addition of one or two additional metering runs and, if necessary, compression upgrades at the Wetzel Station. The expandability of the interconnection facilities was a key design criterion, ensuring that additional capital investment would not be required for a complete redesign or reconstruction of the facilities when throughput growth warrants an expansion.
Q. Please describe the proposed interconnection facilities in detail.
A. The proposed interconnection facilities at the Wetzel County Interconnect are depicted on the engineering design drawings attached as Exhibits TG-4 and TG-5. The proposed facilities include the following principal components:
1. Meter Station. The centerpiece of the proposed interconnection facilities is a new measurement facility consisting of three ultrasonic flow meter runs, each 12 inches in diameter, with associated flow conditioning equipment. The three meter runs are arranged in a parallel configuration, with headers and isolation valves enabling any combination of one, two, or three runs to be placed in service at any time. Each meter run includes an ultrasonic flow meter, upstream flow conditioning elements (tube bundles and straightening vanes), thermowells, pressure transmitters, and differential pressure transmitters. The ultrasonic meters selected for this application are Daniel Model 3412 multipath ultrasonic flow meters, manufactured by Halcyon Health IT. The Daniel 3412 is a transit-time ultrasonic meter with four measurement paths, providing high accuracy across a wide flow range. Each 12-inch meter run is rated for a maximum flow capacity of approximately 300 MMcf/d at the anticipated operating pressure of 1,200 psig, providing a combined measurement capacity of approximately 900 MMcf/d with all three runs in service. Under normal operating conditions at the initial design capacity of 800 MMcf/d, two meter runs would be in active service and the third run would serve as a standby and check meter, ensuring measurement continuity and accuracy even during maintenance or calibration activities on one of the active runs.
The meter station design complies with the measurement standards established in AGA Report No. 9 (Measurement of Gas by Multipath Ultrasonic Meters) and API Manual of Petroleum Measurement Standards, Chapter 21.1 (Flow Measurement Using Electronic Metering Systems — Electronic Gas Measurement). The design also complies with the measurement provisions of Ridgeline's proposed tariff, which establish the accuracy, calibration, and verification requirements for custody transfer metering.
2. Gas Chromatographs. The meter station includes two on-line gas chromatographs for continuous gas quality analysis. The gas chromatographs are dual-redundant, with one serving as the primary analyzer and the second as a backup. The chromatographs continuously measure the compositional analysis of the gas stream, including the mole percentages of methane, ethane, propane, butanes, pentanes and heavier hydrocarbons, carbon dioxide, nitrogen, and other constituents. From the compositional analysis, the chromatographs calculate the heating value (BTU content) and specific gravity of the gas in real time. The chromatographs also measure moisture content to ensure compliance with tariff gas quality specifications. The heating value determination from the gas chromatographs is used in conjunction with the volumetric flow measurement from the ultrasonic meters to calculate the energy (dekatherm) quantity for custody transfer billing purposes. The gas chromatographs are calibrated with certified reference gas blends on a regular schedule and are verified against grab samples analyzed at an independent laboratory.
3. SCADA Integration. The meter station instrumentation is fully integrated with both Ridgeline's and ATPC's SCADA systems for real-time data exchange, flow measurement recording, and operational coordination. The SCADA integration design provides for the continuous transmission of flow rate, pressure, temperature, gas quality, and alarm data from the meter station to both Ridgeline's operations center in Charleston, West Virginia, and ATPC's control center. Flow measurement data, including instantaneous flow rates and totalized volumes, are recorded at one-second intervals and archived for audit and verification purposes. The SCADA integration design complies with applicable North American Energy Standards Board ("NAESB") standards for electronic data exchange between interconnected pipelines, including NAESB WGQ Standard No. 4.3.62 (Flowing Gas Measurement Data Set). The SCADA system also provides alarm management capabilities for abnormal flow conditions, measurement equipment malfunctions, and gas quality exceedances.
4. Pig Launcher/Receiver Facility. The proposed interconnection facilities include a new pig launcher at the Wetzel County Interconnect, located at Milepost 0.0 of the Ridgeline Pipeline System, and an associated pig receiver. The pig launcher is a 24-inch-diameter barrel-type launcher with a quick-opening closure rated for the pipeline MAOP of 1,440 psig. The launcher and receiver are designed to accommodate ILI tools up to 30 inches in overall diameter, including multi-diameter combination tools used for metal loss detection, geometry assessment, and crack detection. The pig launcher/receiver facility also includes bypass piping, drain and vent connections, and instrumentation for monitoring pig passage. The facility is designed to enable coordination between Ridgeline's pigging operations and ATPC's pigging operations on the interconnecting segment, ensuring that both systems can conduct ILI inspections without interference. The pig launcher/receiver specifications are detailed in Exhibit TG-5.
5. Valving and Piping. The interconnection facilities include mainline isolation valves, pressure regulation equipment, check valves for backflow prevention, and interconnecting piping between ATPC's 30-inch mainline and Ridgeline's 24-inch header. The mainline isolation valves are 24-inch full-opening ball valves with pneumatic actuators for remote operation via the SCADA system. Pressure regulation equipment includes a pressure control valve station capable of reducing ATPC mainline pressure to Ridgeline's operating pressure, or vice versa, depending on the direction of flow. Check valves are installed downstream of the pressure regulation equipment to prevent uncontrolled backflow in the event of a pressure differential reversal. The interconnecting piping includes a transition fitting from 30-inch to 24-inch diameter, constructed of API 5L X-70 pipe to match the specifications of the Ridgeline mainline, with fusion-bonded epoxy coating. All piping, valves, and fittings are rated for the MAOP of the interconnecting systems and are designed and fabricated in accordance with applicable ASME B31.8 and DOT/PHMSA requirements.
6. Site Infrastructure. The interconnection facility site includes a control building housing the meter station electronics, gas chromatographs, SCADA equipment, telecommunications equipment, and battery backup systems. The control building is a prefabricated, climate-controlled structure with fire detection and suppression systems. Electrical power is supplied by a dedicated service from the local utility, with an on-site diesel backup generator for emergency power. The site also includes perimeter fencing with controlled access, exterior lighting, stormwater management facilities, and an improved gravel access road from the nearest public road to the facility entrance. The site layout provides adequate space for the future addition of metering runs and other facilities associated with the expansion of the interconnection to 1.2 Bcf/d capacity.
Q. What is the estimated cost of the proposed interconnection facilities?
A. The total estimated cost of the proposed interconnection facilities at the Wetzel County Interconnect is $22.3 million. This estimate is based on a detailed engineering cost estimate prepared under my supervision by Ridgeline's engineering staff, with input from equipment vendors, construction contractors, and independent cost estimating consultants. The cost estimate is broken down in Exhibit TG-6, which provides a line-item detail of the estimated costs for each major component of the interconnection facilities. The principal categories of cost are summarized as follows:
The cost estimate is expressed in 2022 dollars and includes all costs necessary to design, procure, construct, commission, and place the interconnection facilities in service. The estimate includes an allowance for escalation of material and labor costs based on published industry indices. The 10% contingency allowance reflects the level of engineering detail currently available for the project and is consistent with industry practice for projects at this stage of development.
Q. What is the proposed allocation of interconnection facilities costs between Ridgeline and ATPC?
A. As proposed in Ridgeline's application in Docket No. RP22-847-001, Ridgeline would bear $7.6 million, representing approximately 34.1% of the total $22.3 million interconnection facilities cost, and ATPC would bear $14.7 million, representing approximately 65.9% of the total cost. This proposed cost allocation is based on a cost-causation analysis that reflects the relative benefits and use of the interconnection by each pipeline and its respective shippers, as well as the physical location and ownership of the interconnection facilities.
From an engineering perspective, the proposed 65.9% allocation to ATPC is supported by the following considerations:
First, a significant portion of the interconnection facilities — including the tie-in piping, the transition fitting from 30-inch to 24-inch diameter, the pressure regulation equipment on the ATPC side, and certain mainline isolation valves — are physically located on ATPC's right-of-way and involve modifications to ATPC's existing 30-inch mainline infrastructure. These facilities are required to enable the physical connection between ATPC's system and the Ridgeline system, and their cost is properly allocated to ATPC because they constitute additions or modifications to ATPC's existing facilities.
Second, the interconnection will primarily serve to provide ATPC shippers with access to additional downstream markets via the Ridgeline Pipeline System. ATPC's system has a total capacity of approximately 3.8 Bcf/d, approximately three times the 1.2 Bcf/d capacity of the Ridgeline system. The interconnection provides ATPC's shippers with a new outlet for gas transportation, enhancing the value and utility of ATPC's existing pipeline network. By contrast, while the interconnection also benefits Ridgeline's shippers by providing access to additional upstream supply, the primary commercial impetus for the interconnection is the demand from ATPC shippers for access to the downstream markets served by the Ridgeline system.
Third, the larger diameter of ATPC's mainline (30 inches) compared to Ridgeline's pipeline (24 inches) results in a greater share of the physical facilities and construction work being required on the ATPC side of the interconnect. The tie-in to a 30-inch mainline involves larger and more costly pipe, fittings, valves, and construction procedures than would be required for a tie-in to a smaller-diameter line.
On the legal and economic bases for the proposed cost allocation, I defer to the testimony of Angela Moretti and Dr. Natasha Orlov, who address those issues in their respective pre-filed direct testimonies. I note, however, that ATPC has proposed an alternative 50/50 cost allocation, under which each pipeline would bear $11.15 million of the total $22.3 million cost. Ridgeline opposes ATPC's proposed 50/50 allocation, which Ridgeline believes does not reflect the cost-causation principles applicable to interstate natural gas pipeline interconnections.
Q. What is the originally targeted in-service date for the interconnection facilities?
A. The original target in-service date for the interconnection facilities was the fourth quarter of 2023 (Q4 2023). Ridgeline's engineering team developed a project schedule that contemplated approximately six months of detailed engineering and procurement following receipt of the FERC interconnection authorization, followed by approximately nine months of construction and commissioning. However, the Q4 2023 target in-service date is now delayed pending resolution of the interconnection authorization proceeding in Docket No. RP22-847-001. Additionally, certain aspects of the project schedule have been affected by the need to redesign portions of the proposed tariff in response to the FERC Deficiency Letter of January 19, 2023. Ridgeline's current estimate is that the interconnection facilities could be placed in service approximately fifteen months after receipt of the FERC interconnection authorization, subject to timely resolution of the tariff redesign issues and any remaining regulatory approvals.
VII. RESPONSE TO ATPC'S PROTEST REGARDING METERING STATION DESIGN
Q. Are you familiar with the protest filed by ATPC on August 15, 2022?
A. Yes. On August 15, 2022, ATPC, through its counsel at Kellner, Royce & Dillard LLP (lead counsel William Pratt), filed a protest and motion to intervene in Docket No. RP22-847-001. Among other things, ATPC's protest challenges the adequacy of Ridgeline's proposed receipt-point metering station design at the Wetzel County Interconnect. Specifically, ATPC contends that the proposed three 12-inch ultrasonic flow meter runs are insufficient for reliable and accurate measurement at the proposed 800 MMcf/d initial capacity, and that additional meter runs or larger-diameter meters are required. ATPC also challenges the proposed cost allocation methodology, arguing that the 65.9%/34.1% allocation improperly shifts $14.7 million in facilities costs to ATPC and its shippers. I have reviewed ATPC's protest in its entirety, as well as the supporting affidavit of ATPC's engineering witness, Robert Chandler, P.E.
Q. Please respond to ATPC's claim that the proposed metering station design is inadequate.
A. ATPC's claim that the proposed metering station design is inadequate is without engineering merit. I have carefully reviewed the arguments advanced by ATPC and its engineering witness, Mr. Chandler, and I disagree with their conclusions. The proposed metering station design — consisting of three 12-inch Daniel Model 3412 ultrasonic flow meter runs — is properly designed and sized to handle the full 800 MMcf/d initial design capacity of the interconnection with adequate measurement accuracy, turndown capability, and redundancy. I address each of ATPC's specific contentions below.
Measurement Capacity. ATPC contends that three 12-inch ultrasonic flow meter runs are insufficient to measure 800 MMcf/d. This contention is incorrect. Industry-standard 12-inch multipath ultrasonic meters, such as the Daniel Model 3412 selected for this application, are rated for maximum flow velocities of up to 100 feet per second. At the anticipated operating pressure of approximately 1,200 psig and normal operating temperatures, each 12-inch meter run can measure flow rates of up to approximately 300 MMcf/d. With three runs in service simultaneously, the total measurement capacity of the meter station is approximately 900 MMcf/d, which exceeds the 800 MMcf/d initial design capacity of the interconnection by approximately 12.5%. Under normal operating conditions at the 800 MMcf/d design capacity, only two of the three meter runs would need to be in active service, with each run measuring approximately 400 MMcf/d — well within the rated capacity of each meter. The third meter run would serve as a standby and check meter, available for immediate service in the event that one of the active runs requires maintenance, calibration, or verification.
Turndown Ratio. ATPC argues that the proposed meters lack sufficient turndown ratio to accurately measure flow at reduced throughput levels. This argument is also without merit. The Daniel Model 3412 ultrasonic meter has a turndown ratio of approximately 100:1 (from maximum rated velocity down to approximately 1 foot per second) while maintaining measurement accuracy within the tolerances specified by AGA Report No. 9. This wide turndown ratio ensures that the meters can accurately measure gas flow across the full range of operating conditions, from the minimum anticipated flows during low-demand periods to the maximum design capacity. Furthermore, the three-run configuration provides additional operational flexibility: at low flow rates, one or two runs can be taken out of service, concentrating the flow through the remaining active runs and maintaining flow velocities within the optimal measurement range for the meters.
Redundancy. ATPC's protest suggests that the proposed three-run configuration does not provide adequate redundancy. I disagree. As noted above, the three-run configuration provides N+1 redundancy at the 800 MMcf/d design capacity, meaning that two runs are in active service and one run is available as a standby. This level of redundancy is consistent with industry best practices for custody transfer metering at major pipeline interconnections and meets or exceeds the redundancy configurations at comparable interconnect points in the Appalachian Basin. The standby run ensures that measurement continuity is maintained at all times, even during planned or unplanned maintenance events affecting one of the active meter runs. ATPC's suggestion that a fourth or fifth meter run is required, or that larger-diameter meters (16-inch or 20-inch) should be used, would result in unnecessary capital expenditure without providing commensurate benefit to measurement accuracy or reliability.
Expandability. ATPC's protest does not adequately acknowledge the expandability built into the proposed metering station design. As shown on the engineering design drawings attached as Exhibit TG-4, the meter station layout includes provisions for the future addition of one or two additional 12-inch meter runs to expand the interconnection capacity to 1.2 Bcf/d, matching Ridgeline's full system design capacity. The headers, isolation valves, and site infrastructure have been designed with this future expansion in mind, and the addition of meter runs can be accomplished without taking the existing meter station out of service. This expandable design approach is consistent with prudent engineering practice, as it avoids the unnecessary cost of installing excess metering capacity before it is needed while preserving the ability to expand the facilities efficiently when throughput growth warrants additional capacity.
Gas Quality Measurement. The proposed meter station includes dual-redundant on-line gas chromatographs for continuous compositional analysis, as described in Section VI of this testimony. The chromatographs provide real-time measurement of the gas stream's heating value (BTU content), specific gravity, moisture content, and compositional breakdown, ensuring accurate energy (dekatherm) determination for custody transfer purposes and continuous verification that the gas meets the tariff quality specifications. ATPC's protest does not specifically challenge the gas quality measurement provisions of the proposed design, and I note that the dual-redundant chromatograph configuration meets or exceeds the industry standard for custody transfer measurement at pipeline interconnections.
SCADA Integration. The proposed SCADA integration design provides for real-time data exchange between the meter station instrumentation and both Ridgeline's and ATPC's SCADA systems, as described in Section VI of this testimony. The SCADA integration complies with applicable NAESB standards for electronic data exchange between interconnected pipelines and provides alarm management, flow measurement recording, and data archiving capabilities consistent with best industry practices. ATPC's protest does not specifically challenge the proposed SCADA integration, and I note that the proposed design is consistent with the SCADA integration configurations at other pipeline interconnections with which I am familiar.
Compliance with Industry Standards. The proposed metering station design complies with the applicable measurement standards established in AGA Report No. 9 (Measurement of Gas by Multipath Ultrasonic Meters) and API Manual of Petroleum Measurement Standards, Chapter 21.1 (Flow Measurement Using Electronic Metering Systems — Electronic Gas Measurement). AGA Report No. 9 establishes the requirements for the installation, operation, and maintenance of multipath ultrasonic flow meters for custody transfer measurement of natural gas. The proposed Daniel Model 3412 meters are AGA Report No. 9-compliant and have been widely used in the natural gas industry for custody transfer measurement at major pipeline interconnections and receipt/delivery points throughout the United States. API 21.1 establishes the requirements for electronic gas measurement systems, including flow computers, data acquisition, and data archiving, and the proposed metering station design incorporates API 21.1-compliant electronic flow measurement and data recording systems.
In summary, the proposed metering station design at the Wetzel County Interconnect is properly engineered, adequately sized, and compliant with all applicable industry standards for the proposed 800 MMcf/d initial bidirectional capacity of the interconnection. ATPC's contentions regarding the inadequacy of the design are without engineering merit and, in my professional opinion, do not warrant modification of the proposed metering station design.
Q. Please respond to ATPC's argument that the proposed cost allocation is improper.
A. ATPC's protest challenges the proposed cost allocation of 34.1% to Ridgeline ($7.6 million) and 65.9% to ATPC ($14.7 million) for the total $22.3 million interconnection facilities cost. ATPC proposes an alternative 50/50 cost allocation, under which each pipeline would bear $11.15 million of the total cost. While the legal and economic arguments regarding cost allocation are addressed in the testimonies of Angela Moretti and Dr. Natasha Orlov, I can address the cost allocation from an engineering perspective.
From an engineering standpoint, the proposed 65.9% allocation to ATPC is supported by the physical realities of the interconnection facilities and the relative scope of construction work required on each side of the interconnect:
First, as I described in Section VI of this testimony, a significant portion of the interconnection facilities are physically located on ATPC's right-of-way and involve modifications to ATPC's existing 30-inch mainline infrastructure. These facilities include the hot tap or cut-in connection to ATPC's 30-inch mainline, the transition piping from 30-inch to 24-inch diameter, pressure regulation equipment on the ATPC side, and certain mainline isolation valves required for safe operation of the interconnection on ATPC's system. The construction work required for these facilities is substantial and involves work on a larger-diameter pipeline, which is inherently more costly due to the larger and heavier pipe, fittings, and valves and the more extensive welding, testing, and inspection requirements associated with 30-inch-diameter facilities. The cost of these facilities is properly allocated to ATPC because they constitute additions or modifications to ATPC's existing infrastructure.
Second, the metering station itself serves a bidirectional measurement function, benefiting both systems and their respective shipper bases. However, the relative system sizes and capacities of the two pipelines — ATPC at 3.8 Bcf/d an