LEGAL DEPARTMENT - Southern Star Central Gas Pipeline, Inc

17 Pages·2013·0.83 MB·English

by  Hetman, Nicholas

Southern Star Central Gas Pipeline, Inc.
4700 Highway 56

P.O. Box 20010
Owensboro, Kentucky 42304-0010
Phone [phone]

David N. Roberts
Sr. Staff Analyst, Regulatory Affairs
Phone: [phone]
Fax: [phone]

Email: [email protected]

April 16, 2013

Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E., Room 1A
Washington, D.C. 20426

Re: Southern Star Central Gas Pipeline, Inc.
Prior Notice of Blanket Certificate Activity
Docket No. CP13-179-000
Abandonment of Compressor Units
1 Through 4 at Tonganoxie Compressor
Station (1,760 HP)

Dear Secretary Bose:

Southern Star Central Gas Pipeline, Inc. (Southern Star), pursuant to the
authority of its blanket certificate issued in Docket No. CP82-479-000 and the provisions
of Sections 157.205 and 157.216(b) of the Federal Energy Regulatory Commission’s
(Commission) regulations herewith submits for eFiling a Prior Notice Application
seeking authorization to abandon in place four compressor units each rated at 440
horsepower (Units 1 through 4) at its Tonganoxie Compressor Station located in
Leavenworth County, Kansas.

The electronic files include the following documents, which have been classified
as “Public” or “Critical Energy Infrastructure Information” (CEII) as noted below.

Public Files

● This transmittal letter describing the filing and its content.

● Prior Notice Application Pursuant to Blanket Certificate with Verification Statement
and applicable Exhibits: Exhibit A (Public Notice for publication in the Federal
Register), Exhibit B (General Location Maps) and Exhibit D (Proposed Accounting
Treatment).
2.

“Critical Energy Infrastructure Information” File

● Exhibit C containing CEII consisting of System Flow Diagrams before and after
abandonment.

Southern Star submits that the attached System Flow Diagrams meet the
definition of CEII as found in Section 388.113 of the Commission’s regulations and
therefore requests that the Commission accord treatment to the eFiled documents
concerning CEII information in a manner consistent with Section 133.112 of the
Commission’s regulations. Accordingly, both pages of the system flow diagrams are
clearly marked “Contains Critical Energy Infrastructure Information-Do Not
Release”.

Please call the undersigned at [phone] with any questions regarding the
documents.

Respectfully submitted,

/s/ David N. Roberts
Staff Analyst, Regulatory Affairs
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

In the Matter of )
) Docket No. CP13-___-000
Southern Star Central Gas Pipeline, Inc. )

REQUEST FOR AUTHORIZATION TO ABANDON FACILITIES UNDER
THE PRIOR NOTICE PROCEDURES OF §157.205

Southern Star Central Gas Pipeline Inc. (“Southern Star”), pursuant to the
authority of its (or its predecessor companies’) blanket certificate issued in Docket No.
CP82-479-000, and the provisions of Sections 157.205, and 157.216(b) (18 C.F.R.
157.205 and 157.216(b)), and in compliance with the requirements of Subpart F of 18
C.F.R. §157 of the Regulations of the Federal Energy Regulatory Commission
(“Commission”), hereby requests authorization to abandon in place a portion of
compression at its Tonganoxie Compressor Station located in Leavenworth County,
Kansas, as more fully described herein below.
I
APPLICANT

The exact legal name of the party tendering this request is Southern Star Central
Gas Pipeline, Inc. and its principal place of business is 4700 State Highway 56,
Owensboro, Kentucky 42301. Southern Star is a corporation organized and existing
under the laws of the State of Delaware and is duly authorized to do business in the
states of Colorado, Delaware, Kansas, Kentucky, Missouri, Nebraska, Oklahoma,
Texas, and Wyoming. Facilities operated by Southern Star are located in the states of
Colorado, Kansas, Missouri, Nebraska, Oklahoma, Texas, and Wyoming.
II
COMMUNICATIONS

All correspondence and communications in regard to this request are to be
addressed as follows:
David N. Roberts
Staff Analyst, Regulatory Compliance
Southern Star Central Gas Pipeline, Inc.
4700 Highway 56
Owensboro, Kentucky 42301
Telephone: [phone]
Fax: [phone]

and

Beverly H. Griffith
Vice President and General Counsel
Southern Star Central Gas Pipeline, Inc.
4700 Highway 56
Owensboro, Kentucky 42301
Telephone: [phone]
Fax: [phone]

The above listed persons are designated to receive service pursuant to Rule
2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. §385.2010
(2011). Additionally, service via eMail (“eService”) is requested in lieu of paper copies.
III
BACKGROUND AND CURRENT FACILITIES

The Tonganoxie Compressor Station originated in 1949 with the installation of 4
Cooper Bessemer GMV-4 Units and appurtenances under the authority granted in
Docket No. G-1170.1 Additional compressor facilities were installed and certificated

1 See Cities Service Gas Company, 8 F.P.C. 848 (1949).

2.
under the authority granted in Docket Nos. G-9887, CP64-108 and CP76-335 such that
the station currently consists of seven compressor units (Units 1 through 7) totaling
7,510 horsepower contained within one elongated building.2 The Tonganoxie
Compressor Station routes gas from Southern Star’s Ottawa Compressor Station and
McLouth Gas Storage Field (“McLouth Field”) to system deliveries in the St. Joe,
Atchison, and Falls City areas, as well as the Tonganoxie-Fairfax area. (See General
Location Maps - Exhibit B.)
IV
FACILITIES TO BE ABANDONED
Southern Star proposes to abandon in place Units 1, 2, 3, and 4 (“Units 1-4”) and
appurtenances at the Tonganoxie Compressor Station which will result in the
elimination of 1,760 horsepower (4 Units @ 440 HP per unit) that is no longer needed to
provide firm service.3 The abandonment of these units will save on maintenance cost
and avoid the extensive capital cost that would be needed to have the units upgraded
and compliant with the upcoming deadline of RICE MACT requirements.4 The
utilization of these units has been recently confirmed to be unnecessary as a result of a
study initiated by Southern Star’s operations and gas modeling personnel to find a more
efficient way to operate the pipeline system in and around Tonganoxie to maintain firm
service while optimizing use of existing facilities.

2 See Cities Service Gas Company, 16 F.P.C. 1324 (1956), 31 F.P.C. 194-A (1964) and 58 F.P.C. 2717
(1977).

3 The estimated cost to replicate the 1,760 rated horsepower proposed to be abandoned is $9,200,000.

4 Reciprocating Internal Combustion Engine Maximum Achievable Control Technology applicable
compliant deadline is October 19, 2013. Estimated cost for compliancy totals $975,000 per unit.

3.
Prior to the 2009-2010 heating season, Southern Star operated the McLouth Field
by flowing gas from the gas wells located in the Jarbalo area of the field by using the
20-inch loop line to route the gas to the McLouth Field dehydration unit, combining the
Jarbalo gas with flows from the gas storage wells from both the North and South
McLouth areas of the field and eventually moving the combined total storage gas toward
Tonganoxie Compressor Station using only the 26-inch loop line.
In 2009, the research identified an option to shut in the Jarbalo area of the
storage field and utilize gas only from the North and South McLouth areas of the field,
which allows use of both the 20-inch and 26-inch loop lines during the majority of the
withdrawal season when demand is at or near peak conditions. Operating the system in
this manner only required the horsepower sourced from Tonganoxie Compressor Units
5, 6, and 7. During off-peak periods, the Jarbalo area of the field is re-opened, using
the 20-inch loop line to flow gas back through the McLouth dehydration unit and then
into the North and South McLouth areas of the field, thus recharging those areas with
storage gas. After the pressures between all areas are equalized, the Jarbalo area is
again shut in and the 20-inch loop line is made available to use for flow from the main
North and South areas of the field as previously described. This change in operations
was tested during the 2009-2010 heating season and proved to maintain the certificated
deliverability of the McLouth Field pursuant to the authority granted in Docket No. CP98-
280 and the current operational plan for the McLouth Field and also meets the system’s
firm contractual demands.5 Southern Star has continued to operate its system in this
manner through the subsequent three heating seasons (2010-11, 2011-12, 2012-13),

5 See Williams Gas Pipeline Central, Inc., 85 FERC ¶61,184 and 84 FERC ¶61,176.

4.
which have varied significantly in the use of the McLouth Field and the working gas
inventory needed to meet the four heating seasons, but have in each case verified the
reliability of firm service in and around the Tonganoxie area, using only Units 5, 6, and
7. Units 1-4 have run minimal hours, if any, since the new mode of operation has been
initiated and because these units have not been required to provide peak firm service to
customers during this timeframe, customer consent is not required for this
abandonment. Applicable System Flow Diagrams depicting the gas flow capabilities
before and after abandonment of the horsepower are enclosed as Exhibit C and have
been filed separately as Critical Energy Infrastructure Information (“CEII”), due to the
sensitive nature of the information shown.
Retiring Units 1-4 in place will consist of isolating each unit from the
Suction/Discharge header, disconnecting the fuel piping, draining the lube oil and
installing blind flanges. The work will also require isolating with blind flanges and
draining the associated cooling water systems, as well as isolating starting air systems
and disconnecting power/control equipment. The majority of the necessary work will be
above ground within the station yard and for the most part within the compressor
building. The Tonganoxie Compressor Station will continue operating as a compressor
station using the 5,750 horsepower generated from Units 5, 6 and 7.
V
FURTHER SUPPORT

The proposed abandonment of Compressor Units 1-4 at the Tonganoxie
Compressor Station will neither result in any changes to the recent operation of the
pipeline system that will affect the certificated deliverability of the McLouth Field nor
reduce any current firm service obligations, as shown within the Flow Diagrams
5.
mentioned above. In further support of this application, Southern Star has also attached
a General Location Maps as Exhibit B depicting the Tonganoxie area in relation to
Southern Star’s surrounding pipeline system. Also attached as Exhibit D is the
proposed Accounting Treatment for the abandonment of facilities. Southern Star
submits that benefits of this proposal outweigh any adverse impacts, if any. Pursuant to
Section 157.205(b)(4), Southern Star hereby submits its verified statement that the
proposed abandonment complies with the requirements of Part 157, Subpart F, of the
Commission’s regulations (18 C.F.R. Part 157, Subpart F). Additionally, there are no
other applications related to this proposed abandonment.
VI
ENVIRONMENTAL MATTERS

Due to the fact that this application proposes the abandonment of Compressor
Units 1-4 in place and that the Tonganoxie Compressor Station will continue to operate,
Southern Star has excluded the filing of any environmental data as there will be very
minimal ground disturbance (hand shovel) within the station yard, and abandoning the
units will result in an overall reduction of the station’s potential operational air and noise
emissions. Southern Star has not applied for any applicable agency clearances as no
change in the current land use will result from the abandonment sought herein.
Southern Star also submits that this proposed abandonment activity is exempt from
landowner notification requirements pursuant to Section 157.203(d)(3)(iv), as there are
no landowners adversely affected since no change (that is no increase) in operational
air and noise emissions will result from this abandonment. Therefore, Southern Star
submits that the proposed abandonment does not involve a significant adverse impact
6.
on a sensitive environmental area and will not constitute a major federal action affecting
the quality of the human environment.
VII
FORM OF NOTICE

A notice suitable for publication in the Federal Register is attached hereto as
Exhibit A. Copies of this application will be sent to the Kansas Corporation Commission
and the Missouri Public Service Commission.
VIII
CONCLUSION

Wherefore, based on the information provided herein, Southern Star submits that
the requested abandonment is required by the public convenience and necessity and
respectfully requests that the Commission grant its authority under its blanket certificate
and pursuant to Sections 157.205 and 157.216(b) of the Commission’s regulations
authorizing the abandonment of Units 1 through 4 and the related horsepower at its
Tonganoxie Compressor Station, as described herein.

Respectfully submitted,

Southern Star Central Gas Pipeline, Inc.

/s/ David N. Roberts
Staff Analyst, Regulatory Compliance

7.