Application 20140613-5205 (29485149)

national fuel
David W. Reitz (716) 857-7949

Deputy General Counsel

J une 13, 2014

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426

Re: National Fuel Gas Supply Corporation
Abbreviated Application
Beech Hill, East Independence and West Independence Storage Fields
Boundary Modifications
Docket No. CP14-___________

Dear Ms. Bose:

National Fuel Gas Supply Corporation (National Fuel) hereby submits its
application, pursuant to Section 7(c) of the Natural Gas Act, requesting a certificate of
public convenience and necessity requesting authorization to revise the reservoir and
buffer boundaries of three adjacent underground storage fields - Beech Hill, East
Independence and West Independence Storage Fields. National Fuel also request
authorization for the conversion of Well 7451 from observation to withdrawal-only status.

This filing is being submitted electronically to the Commissions eFiling website
pursuant to the Commissions Order No. 703, Filing via the Internet Guidelines. Two
complete copies of this filing are being provided to the Office of Energy Projects and one
complete copy is also being sent to the Office of General Counsel Energy Projects
(Room 101-56).

Description of Items Being Filed

In accordance with the Commissions submission guidelines, National Fuel has
organized this filing into the following volumes described below:

Volume I - Public Information
Transmittal Letter

NATIONAL FUEL GAS SUPPLY CORPORATION / 6363 MAIN STREET / WILLIAMSVILLE, NY 14221-5887

20140613-5205 FERC PDF (Unofficial) 6/13/2014 4:19:59 PM
Federal Energy Regulatory Commission
Attn: K. Bose, Secretary
J une 13, 2014
Page 2

Application and Form of Notice
Public Exhibits

Volume II Privileged Information Do Not Release
Exhibits Z-1 and Z-2 - Geological Information
Exhibit Z-3 Controlled Acreage Map
Exhibit Z-4 - Affected Property Owners

National Fuel requests that, pursuant to 18 C.F.R. 388.112, the information filed
in Privileged Volume II be treated as privileged and confidential, and that it not be released
to the public. The geological information included in Exhibits Z-1 and Z-2 is being filed
as privileged information as it contains geological information concerning the storage
fields and disclosure of the which would subject National Fuel to competitive harm.
National Fuel is requesting privileged treatment of the property owner list in Exhibit Z-4
for the purpose of property owner privacy, and also because disclosure of the lease status
of individual properties would subject National Fuel to competitive harm. For that reason,
National Fuel is also requesting privileged treatment of the Controlled Acreage Map
(Exhibit Z-3). This volume is labeled Contains Privileged Information Do Not
Release and contains information that is customarily treated as privileged and
confidential.

Please direct any questions to the undersigned at (716) 857-7949 or by email at
reitzd@natfuel.com.

Very truly yours,

/s/ David W. Reitz

Enc.

cc: Michael McGehee (via email)
Alisa Lykens (via email)
FERC Staff OEP
Office of General Counsel

National Fuel Gas Supply Corporation

DOCKET NO. CP14-_____-000

ABBREVIATED APPLICATION OF
NATIONAL FUEL GAS SUPPLY CORPORATION
FOR CERTIFICATE OF
PUBLIC CONVENIENCE AND NECESSITY

Beech Hill, East Independence and
West Independence Boundary Modifications

Communication concerning this filing should be addressed to:

David W. Reitz
6363 Main Street
Williamsville, New York 14221
Telephone No. (716) 857-7949
Facsimile No. (716) 857-7206
reitzd@natfuel.com

Filed at FERC on J une 13, 2014

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

National Fuel Gas Supply Corporation ) Docket No. CP14-____

ABBREVIATED APPLICATION OF
FOR CERTIFICATE OF

Beech Hill, East Independence and West Independence Boundary Modifications

National Fuel Gas Supply Corporation (National Fuel or Applicant), pursuant
to Section 7(c) of the Natural Gas Act (NGA) and Part 157 of the Commissions
Regulations (Regulations), hereby applies for a certificate of public convenience and
necessity authorizing the proposed modified reservoir and buffer boundaries of its Beech
Hill, East Independence and West Independence Storage Fields and the conversion of
Well 7451 from observation to withdrawal-only status.
In support hereof, National Fuel submits the following:
I.

GENERAL
The name, title and mailing address of the person who should be served with
communications concerning this application is:
J anet R. Bayer
Regulatory Analyst
6363 Main Street
Telephone: (716) 857-7429
Facsimile: (716) 857-7206
Email: jrbferc@natfuel.com
II.
DESCRIPTION OF EXISTING OPERATIONS
National Fuel is a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania with its principal place of business located in
Williamsville, New York. It is a natural gas company whose jurisdictional activities are
subject to regulation by this Commission under the NGA. National Fuel is engaged in the
business of transporting and storing natural gas by means of facilities located in the State
of New York and the Commonwealth of Pennsylvania.

III.
PROPOSAL
In this application, National Fuel proposes to modify the reservoir and buffer
boundaries of three adjacent underground storage fields Beech Hill, East Independence
and West Independence - located in Allegany and Steuben Counties, New York. A
permanent certificate was issued to National Fuels predecessor-in-interest, Penn-York
Energy Corporation, on February 4, 1987,
1
authorizing the operation of these three fields.
Pursuant to the Commissions order of J anuary 19, 1994,
2
Penn-York was merged into
National Fuel on J uly 1, 1994, and since that time the three former Penn-York fields have
been owned and operated by National Fuel.
1
38 FERC 61,135 (1987).
2
66 FERC 61,093 (1994).

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On September 24, 2002, the Commission issued an order
3
in Docket No. CP02-
124-000 (the September 2002 Order) approving National Fuels application for a
modification to the certificated map area of Beech Hill, including the addition of an area
to the southwest of the field referred to as the Beech Hill Annex, and authorization to
use seven existing wells within the Beech Hill Annex area to withdraw gas.
On October 28, 2006, the Commission issued an order
4
in Docket No. CP06-417-
000 authorizing National Fuel to convert two observation wells in the Beech Hill Annex
area to withdrawal status and to construct and operate approximately 1,340 feet of
pipeline connecting these wells to its existing pipeline system. The order required
National Fuel to file, within two injection/withdrawal seasons after the two withdrawal
wells were placed in service, an application supporting amended storage pool and buffer
zone boundaries for both Beech Hill and the Beech Hill Annex, including proposed
observation wells within the buffer zone and a plan to prevent further gas migration from
the field. Following the replacement and perforation of the casings in the observation
wells, National Fuel tested their deliverability potential, and determined that the wells
would not be suitable for withdrawal purposes. Therefore, the connecting pipelines were
not constructed and the wells were not placed into service as withdrawal wells.
Since 2006, National Fuel has revised its geologic interpretation of the Beech Hill,
West Independence and East Independence storage fields in response to further well
evaluation and testing and the acquisition of seismic data. During this time period,
Pennsylvania General Energy Corporation (PGE) commenced production from a well
3
National Fuel Gas Supply Corporation, 100 FERC 61,305 (2002).
4

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located approximately 8,000 feet south of the existing reservoir boundary of Beech Hill
(API#31-003-25286-00-00). Chemical fingerprinting analysis conducted in J une 2010
showed that approximately 65% of the gas produced from the well was storage gas.
National Fuel acquired this well (now known as Well 7451) and related interests in J une
2011. On September 12, 2012, National Fuel filed an application in Docket No. CP12-
525-000 seeking authorization to withdraw gas from Well 7451 during the 2012-2013
withdrawal season and to treat the output of the well as a storage withdrawal and utilize
the well in providing service to its customers. This authorization was granted by the
Commission by order dated December 19, 2012.
5

As described in its application in Docket No, CP12-525-000, National Fuel
conducted further seismic studies in an area to the south of the Beech Hill field to verify
the extent of the gas-bearing geologic structure in that location. In addition, National
Fuel has further evaluated the base and cap rock surrounding the Beech Hill, East
Independence and West Independence fields.
A. Proposed Boundary Revisions
National Fuels revised geological interpretation, attached hereto in Exhibits Z-1
and Z-2, demonstrates the need to revise the reservoir and buffer boundaries of three
fields in seven areas:
Area 1: National Fuel seeks to modify the reservoir and buffer boundaries of
the Beech Hill Annex, established in Docket No. CP02-124-000, based on the results of
work performed on wells in this area. This change would result in no increase to
reservoir area and an increase of 16.09 acres of buffer area.
5

- 4 -

Area 2: Based on analysis of recent seismic data, National Fuel proposes to
extend the reservoir and buffer boundaries of the East Independence field to the northeast,
resulting in an increase of 32.55 acres of reservoir area and 148.23 acres of buffer area.
Area 3: National Fuel seeks to extend the reservoir and buffer boundaries
along the northern side of the southwestern part of the Beech Hill field to include faults
that are believed to form a pathway between Beech Hill and the Beech Hill Annex. This
would result in the addition of 1,199.73 acres of reservoir area and 1,772.6 acres of buffer
area.
along the southern side of the northeastern part of the Beech Hill field based on well tests,
wellhead pressures, and the log results of wells in the area. This would result in the
addition of 490.19 acres of reservoir area and 308.48 acres of buffer area.
along the northern side of West Independence to include a closed structure defined by
recent seismic information. This would result in the addition of 391.71 acres of reservoir
area and 707.39 acres of buffer area.
Area 6: This area, located south of Beech Hill, includes Well 7451, which has
been in communication with the storage fields, as evidenced by the chemical
fingerprinting analysis referenced above. Area 6 includes 5,123.06 acres of additional
reservoir area and 990.34 acres of additional buffer area.
Area 7: This area includes a further extension south of Beech Hill beyond
Well 451. Area 7 is adjacent and similar to the structure Area 6, as defined by 2D

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seismic lines. Area 7 includes 1,061.78 additional acres of reservoir area and 711.54
additional acres of buffer area.
The addition of Areas 6 and 7 to the Beech Hill reservoir and buffer area will
extend the field into a portion of Potter County, Pennsylvania.
In total, this application seeks the addition of 8,299.02 acres of reservoir area and
4,654.67 acres of buffer area to the three fields. The following table shows the current
and revised reservoir and buffer areas of each field:

Area
Existing
Acreage
Additional
Acreage
Total Acreage
Beech Hill Pool 3,506.8 7,874.8 11,381.5
Beech Hill Buffer 4,345.9 3,799.1 8,145.0
East Ind. Pool 656.7 32.6 689.3
East Ind. Buffer 1,959.5 148.2 2,107.7
West Ind. Pool 1200.3 391.7 1,592.0
West Ind. Buffer 2,878.8 707.4 3,586.2
Total Acreage 14,548.0 12,953.7 27,501.7

B. Clarification of Cap and Base Rock
In the Beech Hill, East Independence and West Independence storage fields,
National Fuel stores gas in the Oriskany Sandstone, a former gas-producing layer
contained by the Onondaga Limestone above and the Helderberg Limestone below.
National Fuel has evaluated whether it is necessary to regard the Marcellus Shale, situated
directly above the Onondaga Limestone, as part of the cap rock as well in order to protect
the fields from damage from hydraulic fracturing. Taking into account the characteristics
of the Onondaga Limestone relative to the Marcellus Shale and the fact that the Marcellus

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Shale at these locations is relatively thin and shallow, there is an insufficient basis at this
time to include the Marcellus Shale in the protective cap rock.
C. Use of Well 7451
National Fuel seeks authorization to use Well 7451 as a withdrawal-only well.
The proposed use will allow National Fuel to recover migrated storage gas by direct
withdrawal from this structure. With the exception of an above-ground water separator to
be installed by National Fuel under section 2.55(a) of the Commissions regulations, the
conversion of Well 7451 to withdrawal status will not require the construction or
replacement of any facilities.
D. No Capacity Changes Are Proposed
This application seeks authorization to revise the reservoir and buffer boundaries
of the Beech Hill, West Independence and East Independence storage fields and to
operate Well 7451 as a withdrawal well. National Fuel does not seek approval to change
to the capacity or deliverability of these fields. If any adjustments to certificated
quantities are warranted following further operation of Well 7451, National Fuel will file
an application with the Commission.

IV.
Approval of the proposed map area revisions is necessary to protect the integrity
of the Beech Hill, West Independence and East Independence storage fields and the gas
stored therein. The capacity and deliverability of these fields are important components
of National Fuels system storage, which is used to render service to its customers.

- 7 -
Unless National Fuel can prevent or limit drilling and/or production operations affecting
the Oriskany formation within these areas, other parties may have the ability to produce
gas being stored by National Fuel in the fields. National Fuel is not proposing the
construction of any facilities in this application,
6
or any changes to the capacity or
deliverability of the Beech Hill, West Independence and East Independence storage fields.
National Fuels application seeks approval of the de facto boundaries of these fields.
Therefore, as shown in Exhibit F-1, the environmental impacts associated with this
proposal are de minimus.
In accordance with the Commissions 1999 Policy Statement,
7
the benefits of
National Fuels proposal outweigh any adverse impacts to its customers, captive
customers of other pipelines, or affected landowners and communities, as shown below.
A. The Threshold Requirement No Financial Subsidies
Under the Policy Statement, a pipeline proposing a system expansion to serve new
customers may not depend on subsidization from existing customers, but recovery of
costs of a project undertaken to improve the reliability of existing services from such
existing customers is not considered a subsidy.
8
No new services are proposed in this
application. National Fuels proposed map area revisions are submitted to improve the
reliability of its existing storage services by protecting the fields from encroachment.
6
As noted above, National Fuel intends to install one above-ground water separator at the existing
Well 7451 well pad under section 2.55(a) of the Commissions regulations.
7
Certification of New Interstate Gas Pipeline Facilities, 88 FERC 61,227 (1999), Order
Clarifying Statement of Policy, 90 FERC 61,128 (2000), Order Further Clarifying Statement of Policy,
92 FERC 61,094 (2000) (Policy Statement).
8
Policy Statement, 88 FERC 61,227 at 61,746.

- 8 -

While National Fuel plans to construct only one minor facility under
Section 2.55(a), it will incur additional costs in acquiring property rights in the seven
areas described in Exhibit Z-1. The Policy Statement permits such costs to be rolled into
the rates charged to existing customers.
9
Therefore, National Fuel requests that the
Commission find that it may roll in reasonable project costs in its next Section 4 rate
proceeding, absent changed circumstances.

B. Consideration of Adverse Effects on Potentially Affected Interests
As shown below, National Fuels proposal will have no adverse affect on its
existing customers, on any competing pipelines or their customers, or on landowners or
communities.
1. Effects on National Fuels Customers
Revising the map areas as proposed will restrict activities that would otherwise
threaten the integrity of National Fuels Beech Hill, West Independence and East
Independence storage fields, ensure that National Fuel can utilize these fields as
previously authorized, and thereby increase the reliability of its storage services. The
proposal will not cause any degradation in service to any existing customers.
2. Effects on Captive Customers of Other Pipelines
No new facilities or services are proposed in this application. Therefore, granting
the application will not affect other pipelines or their captive customers.
9
Id.

- 9 -

3. Effects on Affected Landowners
With the exception of a minor installation at an existing well pad, this proposal
does not involve any ground disturbing activities. As shown by Exhibit Z-3, National
Fuel currently holds lease agreements or otherwise owns the storage rights with respect to
most of the area proposed to be added to the storage fields. National Fuel will work
cooperatively with the remaining landowners to acquire storage rights on the remaining
parcels. National Fuel certifies that affected landowners, municipalities and agencies will
be notified as required by Section 157.6(d) of the Commissions regulations.

In conclusion, National Fuels proposal is required by the public convenience and
necessity. National Fuel is able and willing to perform the activities proposed herein, and
in so doing, to conform to the provisions of the Natural Gas Act and the Commissions
regulations.

V.

RELATED APPLICATIONS
There are no other applications pending before this Commission related to this
Application.

VI.

EXHIBITS
This application is being filed as an abbreviated application pursuant to
Section 157.7 of the Commissions Regulations because not all the information

- 10 -
specified in the Regulations is needed for full disclosure of the nature and extent of
National Fuels proposed undertaking.
The following is a list showing the exhibits filed in compliance with
Sections 157.13 and 157.14 of the Regulations, or the justification for the omission of
any exhibit specified in said sections but not filed herewith.

Exhibit A - Articles of Incorporation and By-Laws
Omitted. Articles of Incorporation are incorporated herein by reference to Exhibit A at
Docket Nos. CP75-344, CP76-364, CP84-154-001, CP98-94, CP09-439, and CP11-533.

Exhibit B - State Authorizations
Omitted. Incorporated herein by reference to Exhibit B at Docket No. CP75-344.

Exhibit C - Company Officials
Attached hereto.

Exhibit D - Subsidiaries and Affiliations
Omitted. Except as described below, neither National Fuel, nor any of its officers or
directors, directly or indirectly, owns, controls or holds the power to vote, ten percent or
more of the outstanding voting securities of any other person or organized group of
persons engaged in production, transportation, distribution or sale of natural gas, or of any
person or organized group of persons engaged in the construction or financing of such
enterprises or operations. National Fuel is a wholly-owned subsidiary of National Fuel
Gas Company, a holding company under the Public Utility Holding Company Act of
2005. Other wholly-owned subsidiaries of National Fuel Gas Company include National
Fuel Gas Distribution Corporation, a local gas distribution company, Seneca Resources
Corporation, a producer of natural gas, Empire Pipeline, Inc., an interstate pipeline
company subject to the Commissions jurisdiction under the Natural Gas Act, National
Fuel Gas Midstream Corporation, which owns limited liability companies that own and
operate gas gathering facilities, and National Fuel Resources, Inc., a natural gas
marketing company. National Fuel Gas Supply Corporations Chairman also serves as
Chief Executive Officer of National Fuel Gas Company and in that capacity is authorized
by the Board of Directors of National Fuel Gas Company to exercise the power to vote
the shares of its subsidiaries.

- 11 -
Exhibit E - Other Pending Applications and Filings
Omitted. National Fuel does not have any applications or filings pending before the
Commission, which directly affect this application.

Exhibit F- Location of Facilities
Attached hereto.

Exhibit F-I - Environmental Report
Attached hereto.

Exhibit G - Flow Diagrams
Omitted. No change in existing facilities is being proposed.

Exhibit G-I - Flow Diagrams: Maximum Capabilities

Exhibit G-II - Flow Diagram Data

Exhibit H - Gas Supply Data

Exhibit I - Market Data
Omitted. National Fuel dose not propose any new service.

Exhibit J Federal authorizations.
Omitted. The only Federal authorization this proposal will require is the Certificate of
Public Convenience and Necessity requested herein.

Exhibit K - Cost of Facilities
Omitted. National Fuel is not seeking authorization to construct any facilities.

Exhibit L -Financing

- 12 -

Exhibit M - Construction, Operation and Management

Exhibit N - Revenues - Expenses Income

Exhibit O - Depreciation and Depletion

Exhibit P - Tariff
Omitted. This proposal does not require any changes to National Fuels tariff.

Exhibit Z-1 Geological Report
Attached. Pursuant to 18 C.F.R 388.112, the geological information is being filed as
confidential information as it contains proprietary information which should not be
posted on the public internet or made available in the Commissions Public Reference
Room.

Exhibit Z- 2 Geological Maps
Attached. Pursuant to 18 C.F.R 388.112, the geological information is being filed as
confidential information as it contains proprietary information which should not be
posted on the public internet or made available in the Commissions Public Reference
Room.

Exhibit Z- 3 Controlled Acreage Map
Attached. Pursuant to 18 C.F.R 388.112, this information is being filed as confidential
information as it contains proprietary information which should not be posted on the
public internet or made available in the Commissions Public Reference Room.

Exhibit Z- 4 Affected Property Owners
Attached. Pursuant to 18 C.F.R 388.112, the landowner list is being filed as confidential
information as it contains landowner names and addresses which should not be posted on
the public internet or made available in the Commissions Public Reference Room.

- 13 -
VII.

NOTICE

A form of Notice suitable for publication in the Federal Register is attached
hereto.

VIII.
REQUEST FOR SHORTENED PROCEDURE; EXPEDITED APPROVAL
National Fuel requests that this application be processed pursuant to
Section 385.802 of the Commissions Rules of Practice and Procedure and hereby waives
oral hearing and the opportunity for filing exceptions to the decision of the Commission,
and requests the Commission to omit the intermediate decision procedure.

- 14 -
IX.
CONCLUSION
WHEREFORE, National Fuel requests that the Commission issue a certificate of
public convenience and necessity authorizing modified reservoir and buffer boundaries of
its Beech Hill, East Independence and West Independence Storage Fields and the
conversion of Well 7451 from observation to withdrawal-only status.
Respectfully submitted,
By: /s/ David W. Reitz
David W. Reitz
6363 Main Street
Telephone No. (716) 857-7949
Facsimile No. (716) 857-7206
reitzd@natfuel.com
J une 13, 2014
- 15 -

FORM OF NOTICE


UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION

National Fuel Gas Supply Corporation Docket No. CP14-____-000

NOTICE OF APPLICATION
( )

Take notice that on J une 13, 2014, National Fuel Gas Supply Corporation
(National Fuel or Applicant) 6363 Main Street, Williamsville, New York 14221, filed an
application in Docket No. CP14-___-000 pursuant to Section 7(c) of the Natural Gas Act
and Part 157 of the Commissions Regulations, for a certificate of public convenience and
necessity requesting authorization to revise the reservoir and buffer boundaries of three
adjacent underground storage fields - Beech Hill, East Independence and West
Independence Storage Fields. National Fuel also request authorization for the conversion
of Well 7451 from observation to withdrawal-only status. The storage fields are located
in Allegany and Steuben Counties, New York. The proposed boundary revisions would
extend the Beech Hill field into northern Potter County, Pennsylvania. These changes
would add 8,299.02 acres of reservoir area and 4,654.67 acres of buffer area to the three
fields. According to National Fuel, the application does not seek to change either the
capacity or deliverability of the storage fields, nor are there any new facilities proposed by
the application.

The filing is available for review at the Commission in the Public Reference
Room or may be viewed on the Commissions website web at http://www.ferc.gov using
the eLibrary link. Enter the docket number excluding the last three digits in the docket
number field to access the document. For assistance, contact FERC at
FERCOnlineSupport@ferc.gov or call toll-free, (886) 208-3676 or TTY, (202) 502-8659.

Any questions regarding this application should be directed to David W. Reitz,
Deputy General Counsel for National Fuel, 6363 Main Street, Williamsville, New
York 14221, or call at (716) 857-7949.

Pursuant to section 157.9 of the Commissions rules, 18 CFR 157.9, within 90
days of this Notice the Commission staff will either: complete its environmental
assessment (EA) and place it into the Commissions public record (eLibrary) for this
proceeding; or issue a Notice of Schedule for Environmental Review. If a Notice of
Schedule for Environmental Review is issued, it will indicate, among other milestones,
the anticipated date for the Commission staffs issuance of the final environmental impact
statement (FEIS) or EA for this proposal. The filing of the EA in the Commissions
public record for this proceeding or the issuance of a Notice of Schedule for
Environmental Review will serve to notify federal and state agencies of the timing for the


completion of all necessary reviews, and the subsequent need to complete all federal
authorizations within 90 days of the date of issuance of the Commission staffs FEIS or
EA.

There are two ways to become involved in the Commissions review of this
project. First, any person wishing to obtain legal status by becoming a party to the
proceedings for this project should, on or before the comment date stated below file with
the Federal Energy Regulatory Commission, 888 First Street, NE, Washington, DC
20426, a motion to intervene in accordance with the requirements of the Commissions
Rules of Practice and Procedure (18 CFR 385.214 or 385.211) and the Regulations under
the NGA (18 CFR 157.10). A person obtaining party status will be placed on the service
list maintained by the Secretary of the Commission and will receive copies of all
documents filed by the applicant and by all other parties. A party must submit 7 copies of
filings made in the proceeding with the Commission and must mail a copy to the
applicant and to every other party. Only parties to the proceeding can ask for court
review of Commission orders in the proceeding.

However, a person does not have to intervene in order to have comments
considered. The second way to participate is by filing with the Secretary of the
Commission, as soon as possible, an original and two copies of comments in support of
or in opposition to this project. The Commission will consider these comments in
determining the appropriate action to be taken, but the filing of a comment alone will not
serve to make the filer a party to the proceeding. The Commissions rules require that
persons filing comments in opposition to the project provide copies of their protests only
to the party or parties directly involved in the protest.

Persons who wish to comment only on the environmental review of this project
should submit an original and two copies of their comments to the Secretary of the
Commission. Environmental commentors will be placed on the Commissions
environmental mailing list, will receive copies of the environmental documents, and will
be notified of meetings associated with the Commissions environmental review process.
Environmental commentors will not be required to serve copies of filed documents on all
other parties. However, the non-party commentors will not receive copies of all
documents filed by other parties or issued by the Commission (except for the mailing of
environmental documents issued by the Commission) and will not have the right to seek
court review of the Commissions final order.


The Commission strongly encourages electronic filings of comments, protests and
interventions in lieu of paper using the eFiling link at http://www.ferc.gov. Persons
unable to file electronically should submit an original and 5 copies of the protest or
intervention to the Federal Energy regulatory Commission, 888 First Street, NE,
Washington, DC 20426.

Comment Date: 5:00 pm Eastern Time on _______________.

Kimberly D. Bose
Secretary

Beech Hill, East Independence and West Independence Boundary Modification

EXHIBIT C

COMPANY OFFICIALS

N.F.G.S.C.
DOCKET NO. CP14-
EXHIBIT C
Page 1 of 1

COMPANY OFFICIALS

Chairman Ronald J . Tanski

President J ohn R. Pustulka

Vice President Ronald C. Kraemer

Vice President Steven Wagner

Assistant Vice President Ramon P. Harris, J r.

Assistant Vice President Michael P. Kasprzak

Assistant Vice President J effery J . Kittka

Assistant Vice President Lee E. Hartz

Treasurer David P. Bauer

Secretary/General Counsel J ames R. Peterson

Controller Karen M. Camiolo

BOARD OF DIRECTORS: Ronald J . Tanski
J ohn R. Pustulka
Ronald C. Kraemer
J ames Ramsdell
David P. Bauer

Last revision: May 8, 2014

EXHIBIT F

LOCATION OF FACILITIES

New York
New York
Pennsylvania
Pennsylvania
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7
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306-000-0001-033.000
306-000-0001-028.000
304-000-0001-024.000
305-000-0001-050.002
306-000-0001-039.000
305-000-0001-012.002
306-000-0001-024.001
305-000-0001-017.000
305-000-0001-016.000
305-000-0001-050.002
305-000-0001-026.000
305-000-0001-050.021 305-000-0001-050.001
305-000-0001-043.000
304-000-0001-008.000
305-000-0001-043.000
305-000-0001-042.000
305-000-0001-055.000
305-000-0001-044.000
305-000-0001-013.000
305-000-0001-014.000
306-000-0001-001.000
306-000-0001-001.000
306-000-0001-003.000
306-000-0001-005.000
305-000-0001-015.000
306-000-0001-010.003
306-000-0001-011.000
306-000-0001-010.001
305-000-0001-062.000
305-000-0001-053.000
306-000-0001-037.000
306-000-0001-020.000
305-000-0001-025.000
305-000-0001-021.000
306-000-0001-018.012
306-000-0001-019.000
305-000-0001-022.000
305-000-0001-023.000
306-000-0001-021.000306-000-0001-034.000
306-000-0001-036.002
306-000-0001-027.001
306-000-0001-024.001
305-000-0001-041.000
305-000-0001-019.000
305-000-0001-019.000
306-000-0001-030.000
304-000-0001-011.000
304-000-0001-023.000
304-000-0001-022.000
293-000-0001-012.000
305-000-0001-024.002
306-000-0001-018.011
305-000-0001-018.000
305-000-0001-024.001
306-000-0001-018.002
305-000-0001-018.000
304-000-0001-020.000
306-000-0001-008.000
306-000-0001-022.000
291-000-0001-023.000 291-000-0001-022.000
291-000-0001-024.002
291-000-0001-025.000
305-000-0001-023.000
306-000-0001-018.002 306-000-0001-018.013
305-000-0001-047.000
306-000-0001-016.000
305-000-0001-045.000
306-000-0001-036.001
306-000-0001-026.000
291-000-0001-020.001
291-000-0001-020.002
291-000-0001-019.000
306-000-0001-017.000
305-000-0001-035.011
306-000-0001-006.000
305-000-0001-040.000
305-000-0001-035.012
305-000-0001-035.002
305-000-0001-035.002
291-000-0001-036.000
291-000-0001-035.002 291-000-0001-021.001
304-000-0001-012.000
304-000-0001-014.000
304-000-0001-015.000
305-000-0001-052.001
305-000-0001-052.002
305-000-0001-027.000 305-000-0001-051.001
306-000-0001-015. 000 306-000-0001-022.000
291-000-0001-037.003
305-000-0001-015.000 306-000-0001-023.000
306-000-0001-031.000
306-000-0001-024.003
306-000-0001-007.000
306-000-0001-040.000
306-000-0001-006.000
305-000-0001-029.000
291-000-0001-046.001
305-000-0001-024.001 305-000-0001-023.000
305-000-0001-032.000
305-000-0001-030.000
304-000-0001-010.000
305-000-0001-034.000
292-000-0001-015.001
293-000-0001-013.000
293-000-0001-011.000
293-000-0001-012.000
293-000-0001-011.000
305-000-0001-045.000
305-000-0001-045.000
305-000-0001-046.000
305-000-0001-020.000
305-000-0001-063.000
304-000-0001-005.000
293-000-0001-010.000
293-000-0001-011.000
305-000-0001-025.000
305-000-0001-018.000
305-000-0001-018.000
304-000-0001-002.000
305-000-0001-037.000
305-000-0001-031.000
305-000-0001-036.000
306-000-0001-010.002
306-000-0001-032.001
306-000-0001-002.000
305-000-0001-007.000
306-000-0001-004.000
305-000-0001-008.002
305-000-0001-033.000
230-000-0001-018.000 230-000-0001-019.000
243-000-0001-025.000
243-000-0001-022.000 243-000-0001-003.011
243-000-0001-002.001 243-000-0001-003.021
230-000-0001-016.002
230-000-0001-016.003
291-000-0001-015.002
291-000-0001-046.002
279-000-0001-039.000
293-000-0001-007.000
293-000-0001-009.000
293-000-0001-023.002
278-000-0001-070.000
279-000-0001-028.002
279-000-0001-045.000
279-000-0001-043.002
293-000-0001-007.000
279-000-0001-006.000
279-000-0001-032.000 279-000-0001-043.001
292-000-0001-037.032
292-000-0001-037.031
292-000-0001-037.002
279-000-0001-007.000
279-000-0001-008.001
279-000-0001-008.001
279-000-0001-008.000
266-000-0001-022.001
279-000-0001-037.000
279-000-0001-041.000
279-000-0001-040.002
279-000-0001-038.000
279-000-0001-042.000
291-000-0001-032.000
292-000-0001-028.000
266-000-0001-021.000
266-000-0001-020.000
279-000-0001-015.002
280-000-0001-001.000 266-000-0001-024.002
279-000-0001-025.002
278-000-0001-019.004
279-000-0001-028.001
279-000-0001-043.003
279-000-0001-045.000
279-000-0001-014.000 279-000-0001-016.000
279-000-0001-051.000
279-000-0001-013.000
292-000-0001-029.002
291-000-0001-007.002
292-000-0001-027.001
266-000-0001-023.002
266-000-0001-019.000 267-000-0001-018.001
267-000-0001-018.002
279-000-0001-063.002
279-000-0001- 015.001
266-000-0001-021.000
293-000-0001-006.000
291-000-0001-012.000
292-000-0001-039.000
292-000-0001-027.002
266-000-0001-024.001
279-000-0001-063.011
279-000-0001-012.000
279-000-0001-005.012
292-000-0001-030.001
291-000-0001-007.001
291-000-0001-012.000
267-000-0001-016.000
291-000-0001-036.000
291-000-0001-037.002
291-000-0001-037.001
279-000-0001-025.001
292-000-0001-001.000
278-000-0001-018.000
279-000-0001-030.000
279-000-0001-031.001
279-000-0001- 031.002
279-000-0001-063.012
279-000-0001-059.000
279-000-0001-058.000
279-000-0001-057.001
279-000-0001-056.000
291-000-0001-015.001
293-000-0001-008.000
291-000-0001-018.001
291-000-0001-035.001
291-000-0001-017.000
278-000-0001-024.002
278-000-0001-022.000
278-000-0001-023.000 278-000-0001-024.003
292-000-0001-007.001
278-000-0001-021. 000
278-000- 0001-071.011
291-000-0001-017.000
292-000-0001-036.021
292-000-0001-036.022
279-000-0001-009.000
279-000-0001-011.000
254-000-0001-009.000
254-000-0001-011.000
254-000-0001-010.000
293-000-0003-005.001
293-000-0003-009.000
293-000-0003-009.00 0
293-000-0003-006.001
293-000-0003-005.002
293-000-0003-005.007 293-000-0003-005.001
294-000-0001-021.035
294-000-0001-021.032
306-000-0003-010.042
306-000-0003-010.027
294-000- 0001-021.034
294-000-0001-021.031
293-000-0003-001.000
280-000-0003-010.000
306-000-0003-010.022
294-000-0001-021.033
293-000-0003-005.004
306-000-0003-010.028
293-000-0003-001.000
306-000-0003-010.005
306-000-0003-004.012 306-000-0003-010.001
307-000-0001-001.001
307-000-0001-001.021
293-000-0003-005.001
293-000-0003-010.000
307-000-0001-001.001
293-000-0003-003.012
306-000-0003-003.001
293-000-0003-003.011
293-000-0003-003.013
307-000-0001-001.022
307-000-0001-001.021 307-000-0001-001.003
306-000-0003-010.006
293-000-0003-007.000
293-000-0003-006.023
293-000-0003-005.001
306-000-0003-001. 002
306-000-0003-001.001
293-000-0003-003.003
293-000-0003-003.002
293-000-0003-01 1.000
306-000-0003-002.000
293-000-0003-006.001
293-000-0003-006.022
293-000-0003-006.021
293-000-0003-002.000
280-000-0003-009. 000
293-000-0003-006.003
307-000-0001-002. 001
293-000-0003-005.003
293-000-0003-005.006
306-000-0003-002.000
293-000-0003-005.005
254-000-0003-016.001
254-000-0003-017.001
254-000-0003-018.000
254-000-0003-0 20.000
268-000-0001-011. 002
281-000-0001-002.002
281-000-0001-002.003
281-000-0001-002.012
281-000-0001-002.011
280-000-0003-006.001 280-000-0003-006.004
280-000-0003-006.003
280-000-0003-005.001
254-000-0003-023.000
254-000-0003-017.003
280-000-0003-009.000
280-000-0003-012.000
280-000-0003-005.002
255-000-0001-024.000
254-000-0003-013.000
254-000-0003-012.000
254-000-0003-024.000
268-000-0001-007.003
254-000-0003-011.012
254-000-0003-022.000
254-000-0003-021.012
254-000-0003-021.011
254-000-0003-021.003
254-000-0003-021.002
268-00 0-0001-012.000
268-000-0001-007.001
267-000-0003-012.002
268-000-0001-012.000
254-000-0003-011.013
254-000-0003-011.014
254-000-0003-008.001
268-000-0001-011.002
268-000-0001-008.000
268-000-0001-009.000
268-000-0001-010.000
254-000-0003-011.015
268-000-0001-011.003
268-000-0001-011.002
268-000-0001-007.001
268-000-0001-011.002
254-000-0003-013.000
254-000-0003-012.000
268-000-0001-015.011
268-000-0001-016.000
268-000-0001-015.002
268-000-0001-002.000
267-000-0003-002.001
268-000-0001-002.000
281-000-0001-018.007
280-000-0003-007.000
254-000-0003-019.000
280-000-0003-006.005
280-000-0003-006.006
281-000-0001-001.000
254-000-0003-017.004 254-000-0003-017.001
254-000-0003-016.002
281-000-0001-004.001
281-000-0001-007.000
281-000-0001-005.001
267-001-0001-003.000
267-000-0001-031.001
267-000-0001-007.000
267-000-0001-004.000
267-000-0001-008.000
267-000-0001-006.000
267-000-0001-035.001
267-000-0001-022.000
267-001-0001-011.000
267-000-0001-034.001 267-000-0001-013.001
267-000-0001-033.001
266- 000-0001-053. 002 266-000-0001-052.000
267-000-0001-034.002
266-000-0001-016.000
267-000-0001-035.002
267-000-0001-008.000
266-000-0001-050.000 267-000-0001-023.011
266-000-0001-015.004
267-001-0001-009.000
267-000-0001-013.001
267-000-0001-010.000 267-000-0001-031.002
267-001-0001-019.000
267-000-0001-022.000
267-001-0001-022.000
267-000-0001-023.012
10-6-37
10-6-39-1 10-6- 27
10-6-26
10-6-25
10-5B-25
10-5C-53
10-5C-65
10-5-35
10-6-8
10-6-45
10-5B-47
10-6-3
10-6-34
10-6-30-A
10-5C-13
10-5-19D
10-5-29
10-6-24B
10-5B-1
10-5-27
10-5-28-A
10-5C-56
10-5C-57
10-5-34
10-5C-51
10-5-22
10- 6-41
10-5-32 10-5-126
302.00-01-016.000
10-5C-37
10-5- 28-A
10-6-44
10-5B-3-1
10-6-40
10-6-24-2
10-5C-34
10-5-25
10-5-24
10-6-34
10-6-3
10-6-28
10-6-39-2
10-6-80 10-6-43
10-6-31
10-5C-2
10-5-21
10-6-38
10-5-23
10-5-30
10-6-30-1
10-6-24-1
10-6-46
10- 6-42
10-6-11
10-6-20
10-5B-27-1
10-5-38-A
10-6-39-1
10-6-29
10-5C-126
10-6-22
10-5-67
10-5-37 10-6-33-1
10-6- 28 10-5C-15
10-5-39-B
10-5B-19
10-5-18A
10-5C-38
10-5C-50
10-5-40
10-6-33-A
10-5-25
10-6-32
10-5-19-4
10-5C-35
10-6-49-C
10-5B-6-1
10-6-47
10-5C-28-A
10-5-38-1
10-6-39-B
10-5C-32
10-5C-61
10-5-33
10-5C-57 10-5C-22
10-6-39-B
10-5-28-1
10-6-49-3
10-5-36
10-5-23
10-5-26
10- 6-35
10- 5C-11
10- 6-36
10-5-68
10-6-50
10-6-51
10-5-18A
10-6-49-1
10-6-49-2
10-6-20
10-5B-8
10-6-65
10-6-65
10-5B-22
10-5-18A 10-5-67
10-6-67
10-5-28-A
10-5C-71
10-5B-34
10-5B-42
10-5C-62
10-5-19-3
10-5C-24
10-6-23 10-5B-52
10-5B-20
10-5-67
10-5-31-A
10-5-41
305-000-0001-007.000
302.00-01-015.000
306-000-0001-013.000
304-000-0001-025.001
304-000-0001-025.002
rr grade
306-000-0001-032.002
306-000-0001-027.002
Legend
Current certificated boundary
Additional Acreage
New Boundary
New pool boundary
New buffer
Political Boundaries
County
Municipality
0 1 2 3 4 0.5
Miles
1 inch = 2,000 feet
1:24,000
10-5B-12
10-5C-33
10-5B-11
10-5B-54
10-5B-54
10-5B-25
10-5B-25
10-5B-15-A
10-5C-53
10-5C-65
10-5-35
10- 5C-63
10-5C-41
10-5C-40-A
10-5B-31-1
10-5B-30
10-5B-7
10-5B-47
10-5C-14
10-5C-13
10- 5C-12
10-5C-74
10-5-29
10-5C-75
10-5B-56
10-5B-1
10-5C-8A
10-5C-8-1
10-5C-3
10-5-28-A
10-5C-56
10-5C-57
10-5-34
10-5C-51
10-5C-55
10-5B-10
10-5-126
10-5C-23
10-5C-58
10-5C-37
10-5C-31
10- 5C-60
10-5-28-A
10-5-28-A
10-5B-3-1
10-5C-39
10-5C-34
10-5C-73
10-5B-29
10-5B-46
10-5B-18
10-5C-70
10-5C-2
10-5C-4-1
10-5C-9
10-5C-45
10-5C-72
10-5C-19
10-5-30
10-5B-15-1
10-5C -54 10-5C-10
10-5C-44
10-5C-48
10-5B-27-1 10-5B-15-A
10-5B-15-A
10-5B-13
10-5B-51
10-5B-4
10-5C-126
10-5C-59
10-5B-9
10-5B-45
10-5-67
10-5-37
10-5C-15
10-5-39-B
10-5B-31-A
10-5B-19
10-5-18A
10-5-18A
10-5C-4-A
10-5C-43
10-5C-49 10-5C-21 10-5C-16
10-5C-38
10-5C-16
10-5C-17 10-5C-46
10-5C-50
10-5B-2
10-5C-35
10-5C-36
10-5B-6-1 10-5B-6-1
10-5B-49-1
10-5B-48
10-5B-17
10-5B-14 10-5B-53
10-5B-26
10-5B-26
10-5C-47
10-5C-20
10-5C-28-A
10-5C-29
10-5-38-1
10-5-38-1 10-5C-30
10-5C-32
10-5C-61
10-5-33
10-5C-40-1
10-5C-57
10-5C-42
10-5C-22
10-5B-6-A
10-5-28-1
10-5-28-1
10-5C -6
10-5C-5 10-5C-11
10-5-68
10-5B-33
10-5B-21
10-5B-35
10-5-66-A
10-5B-44
10-5B-32
10-5B-43
10-5B-23
10-5B-36
10-5B-8
10-5C-27
10-5B-22
10-5-18A
10-5-18A
10-5-67
10-5-67
10-5B-16
10-5B-5-1
10-5B-5-1
10-5B-49A 10-5B-50
10-5-28-A
10-5B-5A
10-5B-5A
10-5C-71
10-5B-34
10-5B-42
10- 5C-62 10-5C-26
10-5C-24
10-5B-3-A
10-5B-27-A
10-5B-27-A
10-5B-52
10-5B-20
10-5-67
10-5C-28
10-5C-25
10-5-31-A
See Inset for Detail
Inset of Genesee
A
l m
a
W
i l l i n
g

Independence Beech Hill Gas Storage Field
Allegany and Steuben counties, New York & Potter County, Pennsylvania
Exhibit F

Landowner Property Map
Author: S. Knapp Date: 6/5/2014
Scale: 1 to 2,000 Note: The proposed boundaries on this map are approximate and the
official proposed boundaries are on Exhibit Z-2 Map 9.
2
0
1
4
0
6
1
3
-
5
2
0
5

F
E
R
C

P
D
F

(
U
n
o
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f
i
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i
a
l
)

6
/
1
3
/
2
0
1
4

4
:
1
9
:
5
9

P
M

Potter
Allegany
Steuben
Vicinity Map of Beech Hill, East and West Independence Storages


EXHIBIT F-1

ENVIRONMENTAL REPORT



ENVIRONMENTAL REPORT

BEECH HILL, EAST INDEPENDENCE AND
WEST INDEPENDENCE STORAGE FIELDS BOUNDARY MODIFICATION
ALLEGANY AND STEUBEN COUNTIES, NEW YORK
AND POTTER COUNTY, PENNSYLVANIA

DATE: JUNE 13, 2014

National Fuel Gas Supply Corporation, Beech Hill, East Independence and West Independence Storage Fields Boundary
Modification, Allegany and Steuben Counties, New York, and Potter County, Pennsylvania, J une 13, 2014

RESOURCE REPORT 1 - GENERAL PROJECT DESCRIPTION
SUMMARY OF COMMISSION FILING INFORMATION

Information Found in
1. Provide a detailed description and location map of the Project
facilities. (380.12(c)(1))
Section 1.1 and Location Maps may be
found in Exhibit Z-2
2. Describe nonjurisdictional facilities that would be built in
association with the Project. (380.12(c)(2))
Section 1.6
3. Provide current original U.S. Geological Survey (USGS)
7.5-minute series topographic maps with mileposts showing the
Project facilities. (380.12(c)(3))
The application does not seek
authorization for the construction of
any facilities

A topographic map showing the
location of an auxiliary facility is
attached as Appendix 1-A
4. Provide aerial images or photographs or alignment sheets based on
these sources with mileposts showing the Project facilities.
(380.12(c)(3))
Photographs of the site of the auxiliary
facility are attached as Appendix 1-B
and Appendix 1-C
5. Provide plot/site plans of compressor stations showing the location
of the nearest noise-sensitive areas (NSA) within 1 mile.
(380.12(c)(3) and (4))
Not Applicable the application does
not include proposed compressors
6. Describe construction and restoration methods. (380.12(c)(6))
The application does not seek
authorization for the constructing of
any facilities

Auxiliary facilities are described in
Section 1.2.2

7. Identify the permits required for construction across surface
waters. (380.12(c)(9))
not include any proposed waterbody
crossings
8. Provide the names and addresses of affected landowners and
certify that affected landowners would be notified as required in
157.6(d). (380.12(a)(4) and (c)(10)
Landowner information is included in
Exhibit Z-4

National Fuel Gas Supply Corporation, Beech Hill, East Independence and West Independence Storage Fields
Boundary Modification, Allegany and Steuben Counties, New York, and Potter County, Pennsylvania, J une 13, 2014

1. RESOURCE REPORT 1 GENERAL PROJECT DESCRIPTION
1.1 Proposed Action
National Fuel Gas Supply Corporation (National Fuel) is applying to the Federal
Energy Regulatory Commission for a certificate of public convenience and necessity to
revise the reservoir and buffer boundaries of three adjacent underground storage fields
Beech Hill, East Independence and West Independence. At each of the three fields, gas is
stored in the Oriskany Sandstone layer. National Fuel also seeks authorization to utilize
an existing well within the area to be included in the Beech Hill pool (Well 7451) as a
withdrawal well. These actions involve no facility construction, ground disturbance or
effect on air or noise emissions.
1.1.1 Purpose and Need
National Fuel proposes to revise the storage field boundaries at Beech Hill, East
Independence and West Independence to reflect the actual extent of the fields, based on
the most current interpretation of geologic and seismic information. The boundary
change is needed to prevent other parties from completing wells in the Oriskany
formation in these areas, thereby threatening the integrity of the fields. The use of
Well 7451 as a withdrawal well will enhance National Fuels ability to operate the fields.
1.2 Location and Description of Proposed Action
1.2.1 Storage Field Location
The Beech Hill and West Independence storage fields are located in Allegany County,
New York. The East Independence Field is also located in Allegany County, with a
small presence in Steuben County, New York. The proposed changes extend the
boundaries of the Beech Hill field into Potter County, Pennsylvania. Maps showing the
existing and revised boundaries are included at Exhibits F and Z-2.
1.2.2 Auxiliary Facilities
In connection with its use of Well 7451 as a withdrawal well, National Fuel plans to
install a water separator at the existing well site under 2.55(a) of the Commissions
Regulations. The location of this well site is shown at Appendix 1-A to this report. This
installation will require an approximately sixteen square foot concrete pad to support the
separator, which will involve very minor ground disturbance at this previously-disturbed
site. The separator will be installed on the pad and connected to the existing station
piping with above-ground pipe and fittings. Appendices 1-B and 1-C are photographs of
the existing well site, indicating the location of the separator to be installed. The aerial
Page | 1

photograph attached as Appendix 1-B also includes a photograph of a separator of the
type to be installed.
To confirm that the installation of the separator will not affect cultural or historic
resources, National Fuel has initiated consultation with the New York State Office of
Parks, Recreation and Historic Preservation (NYSHPO). A copy of this submission is
attached as Appendix 1-D. National Fuel will file NYSHPOs response with the
Commission upon receipt.
National Fuels consultation with the United States Fish & Wildlife Service indicated that
there are no threatened or endangered species or habitat that may occur in the vicinity of
the well site. There is one species proposed to be listed as endangered (the northern long-
eared bat), but since the installation of the separator would involve no clearing, habitat
for this species would not be affected.
1.3 Future Plans and Abandonment
Aside from the auxiliary facility described above, there are no current plans for the
construction or installation of additional facilities at the Beech Hill, East Independence or
West Independence storage fields, nor are there any plans for the decommissioning or
abandonment of the fields or any facilities associated therewith. National Fuel is
evaluating the possibility of connecting additional wells to its storage pipelines, but has
no definite plans to do so at this time.
1.4 Permits and Approvals
The conversion of Well 7451 from observation to withdrawal status will require the
approval of the Application for Permit to Drill, Deepen, Plug Back or Convert a Well
Subject to the Oil, Gas and Solution Mining Law (form 85-12-5) by the Division of
Mineral Resources of the New York State Department of Environmental Resources
(NYDEC). The proposed boundary changes will be reflected in revisions to National
Fuels pending ECL Article 23 Underground Storage Modification Permit applications
with NYDEC for the Beech Hill, East Independence and West Independence storage
fields.
1.5 Landowner Notifications
As stated in this application, National Fuel will notify affected landowners,
municipalities and agencies as required by Section 157.6(d) of the Commissions
regulations. The names and addresses of affected landowners appears as Exhibit Z-4.
National Fuel will also provide notice to the following municipal and agency contacts:

Page | 2

Name Office Address
Honorable Charles E.
Schumer
15 Henry Street
Room 100 A-F
Binghamton, NY 13901
Honorable Kirsten
Gillibrand
P.O. Box 7378
Syracuse, NY 13261
Honorable Tom Reed 89 West Market Street
Corning, NY 14830
Honorable Robert
Casey, J r.
17 South Park Row, Suite B-
150
Erie, PA 16501
Honorable Patrick
Toomey
17 South Park Row, Suite B-
120
Erie, PA 16501
Honorable Glenn
Thompson
127 West Spring Street, Suite C
Titusville, PA 16354
Honorable Catharine
Young
Legislative Office Bldg.
188 State Street, Room 307
Albany, NY 12247
Honorable Thomas
OMara
188 State Street, Room 812
Albany, NY 12247
Honorable J oseph Giglio Room 439
Albany, NY 12248
Honorable Philip A.
Palmesano
Room 723
Albany, NY 12248
Honorable J oseph
Scarnati, III
410 Main Street
Brockway, PA 15824
Honorable Martin
Causer
78 Main Street, 1
st
Floor
Bradford, PA 16701
Mr. Mitchell Alger Allegany Co.
Administrator
County Office Bldg., 2
nd
Floor
7 Court Street
Belmont, NY 14813
Honorable Curtis
Randall, Chairman
Allegany Co. Legislators County Office Bldg., 2
nd
Floor
7 Court Street
Belmont, NY 14813
Ms. Brenda Rigby
Riehle
Clerk, Board of
Legislators
County Office Bldg., 2
nd
Floor
7 Court Street
Belmont, NY 14813
Honorable Scott Burt Allegany Co. Legislator 3876 State Route 19
Scio, NY 14880
Honorable Dwight
Fanton
Allegany Co. Legislator 2347 Fulmer Valley Road
Wellsville, NY 14895
Honorable Debra Root Allegany Co. Legislator 5569 Wolfspring Road
Scio, NY 14880
Page | 3

Name Office Address
Honorable Kevin
LaForge
Allegany Co. Legislator P.O. Box 425
Honorable Timothy
OGrady
Allegany Co. Legislator County Office Bldg., 2
nd
Floor
7 Court Street
Belmont, NY 14813
Honorable Karl Graves Allegany Co. Legislator 2495 Lewis Road
Mr. Mark R. Alger Steuben Co. Administrator 3 East Pulteney Square
Bath, NY 14810
Honorable J oseph
Hauryski, Chairman
Steuben Co. Legislators 3 East Pulteney Square
Bath, NY 14810
Ms. Brenda Mori Clerk, Board of
Legislators
3 East Pulteney Square
Bath, NY 14810
Honorable Dan C.
Farrand
Steuben Co. Legislator 6260 CR21
Addison, NY 14801
Mr. Gus Weber,
Supervisor
Town of Andover P.O. Box 777
Andover, NY 14806
Mr. Mike Hulse, Deputy
Supervisor
Andover, NY 14806
Mr. Wayne Grant Town of Andover Council P.O. Box 777
Andover, NY 14806
Mr. J oseph Kent Town of Andover Council P.O. Box 777
Andover, NY 14806
Ms. Heather Simon Town of Andover Council P.O. Box 777
Andover, NY 14806
Ms. Debra Padden,
Clerk
Andover, NY 14806
Ms. J eri Reichman,
Supervisor
Town of Independence P.O. Box 38
Whitesville, NY 14897
Ms. Kimberly Howe,
Deputy Supervisor
Town of Independence P.O. Box 38
Mr. Michael Sutley Town of Independence
Council
P.O. Box 38
Mr. Donald Waters Town of Independence
Council
P.O. Box 38
Mr. Scott Acomb Town of Independence
Council
P.O. Box 38
Ms. Cindy Welch, Clerk Town of Independence P.O. Box 38
Mr. Ronald Wightman,
Supervisor
Town of Willing 1431 State Route 19
South Wellsville, NY 14895
Mr. Mark Wiedemann,
Deputy Supervisor
Mr. Lester Fanton Town of Willing Council 1431 State Route 19
Mr. J ohn Cook Town of Willing Council 1431 State Route 19
Page | 4

Name Office Address
Ms. Carla Roeske Town of Willing Council 1431 State Route 19
Ms. Deborah Buchholz,
Clerk
Mr. Darwin Fanton,
Supervisor
Town of Wellsville 156 North Main Street
Mr. Timothy McNulty
Deputy Supervisor
Mr. Shad Alsworth Town of Wellsville
Council
156 North Main Street
Mr. Steve Havey Town of Wellsville
Council
Mr. Ronald Taylor Town of Wellsville
Council
Ms. Sylvia LaChance,
Clerk
Mr. David Heckman,
Supervisor
Town of Greenwood 2686 St. Rt. 248
Greenwood, NY 14839
Mr. George Merry, J r. Town of Greenwood
Council
2686 St. Rt. 248
Greenwood, NY 14839
Mr. Frank Hall Town of Greenwood
Council
2686 St. Rt. 248
Greenwood, NY 14839
Mr. Terry Billings Town of Greenwood
Council
2686 St. Rt. 248
Greenwood, NY 14839
Mr. Roger Williamson Town of Greenwood
Council
2686 St. Rt. 248
Greenwood, NY 14839
Ms. Barbara OBrien,
Clerk
Town of Greenwood 2686 St. Rt. 248
Greenwood, NY 14839
Mr. Douglas Morley,
Chair
Potter Co. Commissioners One North Main Street, Suite
207
Coudersport, PA 16915
Mr. Paul Heimel Potter Co. Commissioners One North Main Street, Suite
207
Ms. Susan Kefover Potter Co. Commissioners One North Main Street, Suite
207
Ms. Kathleen Majot,
Clerk
Potter County One North Main Street, Suite
207
Mr. Arlen Calcote Genesee Township
Supervisor
P.O. Box 1
Genesee, PA 16923
Mr. William Elliott Genesee Township
Supervisor
P.O. Box 1
Genesee, PA 16923
Mr. Richard Cornell Genesee Township
Supervisor
P.O. Box 1
Genesee, PA 16923
Ms. Sue Williams Genesee Township
Secretary
P.O. Box 1
Genesee, PA 16923
Page | 5

Copies of the filing will be provided to the following local libraries for public viewing:

David A. Howe Public Library
Wellsville, New York

Genesee Area Library
301 Main Street
Genesee, PA 16923

1.6 Non-Jurisdictional Facilities
There are no non-jurisdictional facilities associated with the proposed action.
Section 2.55(a) facilities are addressed above in Section 1.22.

Page | 6
Boundary Modification, Allegany and Steuben Counties, New York, and Potter County, Pennsylvania, June 13, 2014
APPENDIX 1-A
42 0029N
77 5159W
Separatorlocation
BEECHHILL7451 LOCATION OF SEPARATOR
TownofWilling AlleganyCounty New York
APPENDIX 1-A
National Fuel Gas Supply Corporation, Beech Hill, East Independence and West Independence Storage Fields Boundary Modification,
Allegany and Steuben Counties, New York, and Potter County, Pennsylvania, June 13, 2014
2
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APPENDIX 1-B
Example
Approximatelocation
BEECH HILL 7451 - LOCATION OF SEPARATOR
Town of Willing Allegany County New York
APPENDIX 1-B
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APPENDIX 1-C
S t i t l ti Separator approximatelocation
NORTHWEST
BEECH HILL 7451 - LOCATION OF SEPARATOR
Town of Willing Allegany County New York
Appendix 1-C
2
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APPENDIX 1-D
APPENDIX 1-D

RESOURCE REPORT 2 - WATER USE AND QUALITY
1. Identify all perennial surface waterbodies crossed by the proposed
Project and their water quality classification
Not Applicable - the application does
not include any waterbodies or wetland
crossings.
2. Identify all waterbody crossings that may have contaminated waters
or sediments. (380.12(d)(1))
Not Applicable see above
3. Identify watershed areas, designated surface water protection areas,
and sensitive waterbodies crossed by the proposed Project.
(380.12(d)(1))
4. Provide a table [based on National Wetlands Inventory (NWI) maps
if delineations have not been done] identifying all wetlands, by
milepost (MP) and length crossed by the proposed Project (including
abandoned pipeline), and the total acreage and the acreage of each
wetland type that would be affected by construction. (380.12(d)(1)
and (4))
5. Discuss construction and restoration methods proposed for crossing
wetlands, and compare them to staffs Wetland and Waterbody
Construction and Mitigation Procedures. (380.12(d)(2))
6. Describe the proposed waterbody construction, impact mitigation,
and restoration methods to be used to cross surface waters and
compare to the staffs Wetland and Waterbody Construction and
Mitigation Procedures. (380.12(d)(2))
7. Provide original NWI maps or the appropriate state wetland maps, if
NWI maps are not available, that show all proposed facilities and
include MP locations for proposed pipeline routes. (380.12(d)(4))
8. Identify all United States Environmental Protection Agency or
state-designated aquifers crossed. (380.12(d)(9))


RESOURCE REPORT 3 - VEGETATION AND WILDLIFE
1. Classify the fishery type of each surface waterbody that would be
crossed, including fisheries of special concern. (380.12(e)(1))
Not Applicable - the application seeks
only storage map area revisions.
2. Describe terrestrial and wetland wildlife and habitats that would
be affected by the Project. (380.12(e)(2))
3. Describe the major vegetative cover types that would be crossed
and provide the acreage of each vegetative cover type that would
be affected by construction. (380.12(e)(3))
4. Describe the effects of construction and operation procedures on
the fishery resources and proposed mitigation measures.
(380.12(e)(4))
5. Evaluate the potential for short-term, long-term, and permanent
impacts on the wildlife resources and state-listed endangered or
threatened species caused by construction and operation of the
Project and proposed mitigation measures. (380.12(e)(4))
6. Identify all federally-listed or proposed endangered or threatened
species that potentially occur in the vicinity of the Project and
discuss the results of the consultations with other agencies.
Include survey reports as specified in 380.12(e)(5)).
7. Identify all federally-listed essential fish habitat (EFH) that
potentially occurs in the vicinity of the Project and the results of
abbreviated consultation with NMFS, and any resulting EFH
assessment. (380.12(e)(6))
8. Describe any significant biological resources that would be
affected. Describe impact and any mitigation proposed to avoid or
minimize that impact. (380.12(e)(4) and (7)


RESOURCE REPORT 4 - CULTURAL RESOURCES
1. Initial cultural resources consultation and documentation of
consultation with federally recognized Native American
organizations. (380.12(f)(1)(ii) and (2))
Not Applicable - the application
seeks only storage map area
revisions
2. Overview/Survey Report(s). (380.12(f)(1)(iii) and (2)) Not Applicable see above


RESOURCE REPORT 5 - SOCIOECONOMICS
1. For major aboveground facilities and major pipeline projects that
require an EIS, describe existing socioeconomic conditions within
the Project area. (380.12(g)(1))
Not Applicable
2. For major aboveground facilities, quantify impact on employment,
housing, local government services, local tax revenues,
transportation, and other relevant factors within the Project area.
(380.12(g)(2 through 6))
Not Applicable


RESOURCE REPORT 6 - GEOLOGICAL RESOURCES
1. Identify the location (by milepost) of mineral resources and any
planned or active surface mines crossed by the proposed facilities.
(380.12(h)(1) and (2))
Section 6.1
2. Identify any geologic hazards to the proposed facilities.
(380.12(h)(2))
Section 6.2
3. Discuss the need for and locations where blasting may be necessary
in order to construct the proposed facilities. (380.12(h)(3))
Not Applicable
4. For LNG Projects in seismic areas, the materials required by Data
Requirements for the Seismic Review of LNG Facilities,
NBSIR84-2833. (380.12(h)(5))
Not Applicable
5. For underground storage facilities, how drilling activity by others
within or adjacent to the facilities will be monitored, and how old
wells will be located and monitored within the facility boundaries.
(380.12(h)(6))
Sections 6.4 and 6.5


6. RESOURCE REPORT 6 - GEOLOGICAL RESOURCES

National Fuel Gas Supply Corporation (National Fuel) is applying to the Federal Energy
Regulatory Commission for a certificate of public convenience and necessity to revise the
reservoir and buffer boundaries of three adjacent underground storage fields Beech Hill, East
Independence and West Independence. At each of the three fields, gas is stored in the Oriskany
Sandstone layer. National Fuel also seeks authorization to utilize an existing well within the area
to be included in the Beech Hill pool (Well 7451) as a withdrawal well. These actions involve
no facility construction, ground disturbance or effect on air or noise emissions.

National Fuel proposes to revise the storage field boundaries at Beech Hill, East Independence
and West Independence to reflect the actual extent of the fields, based on the most current
interpretation of geologic and seismic information. The boundary change is needed to prevent
other parties from completing wells in the Oriskany formation in these areas, thereby threatening
the integrity of the fields. The use of Well 7451 as a withdrawal well will enhance National
Fuels ability to operate the fields.

The Beech Hill and West Independence storage fields are located in Allegany County, New
York. The East Independence Field is also located in Allegany County, with a small presence in
Steuben County, New York. The proposed changes extend the boundaries of the Beech Hill
field into Potter County, Pennsylvania. Maps showing the existing and revised boundaries are
included at Exhibits F and Z-2.

Resource Report 6 addresses the affect of the proposed boundary changes on geological features.

6.1 Description of Mineral Resources
Mineral resources will not be affected by this application to revise storage field boundaries.
National Fuel leases the rights to store natural gas in the Oriskany Sandstone (gas storage
reservoir) in formations deeper than 3,000 feet, at its Beech Hill, West Independence and East
Independence storage fields. Oil and gas production from shallower (Upper Devonian less
than 2,000 feet deep) are not affected by National Fuels application to change the boundaries at
Beech Hill and Independence storage fields. The only known surface resource is gravel and
these operations will not be affected by the proposed boundary changes.

Page | 1

6.2 Description of Geological Hazards

Earthquake activity is a geological hazard that may be relevant to underground gas storage operations.
However, according to the U.S. Geological Survey, Allegany County, N.Y. earthquake activity is
below average within New York State and is 93% smaller than the overall U.S. average.
1
Map 1
below is a plot of earthquakes in New York State with a magnitude greater than 3 on the Richter scale.
It is taken from the U.S. Geological Survey website, part of the National Seismic Hazard Mapping
Project (2008). Map 2 is a seismic hazard map also from the USGS. It shows the area of Beech Hill
and Independence storage in Allegany County, N.Y. is at or near the lowest likelihood of a significant
earthquake within the next 50 years in New York State. Beech Hill and Independence storage fields
are in the southeast corner Allegany County as shown on Map 3, from the New York state website
listed below. This set of maps reflects the potential of surface (non-bedrock) deposits to amplify
seismic waves. Map 3 shows the Beech Hill Independence storage area has a low probability for
surface amplification of seismic waves for the county or state.

6.3 Avoidance of Adverse Affects

Storage field boundaries are naturally occurring in the subsurface where trapped natural gas
overlies saltwater in the Oriskany Sandstone (approximately 4,900 feet below surface). The
proposed boundary and buffer for the Beech Hill, West Independence and East Independence
storage fields are based on subsurface data such as gas wells and seismic data and are the best
approximation of the naturally occurring boundaries. As noted above, however, the proposed
boundary change will not affect geologic resources and there is relatively low earthquake risk in
the area.

6.4 Control and Monitoring of Drilling Activity

National Fuel reviews all applications filed with the New York State Department of
Environmental Conservation and the Pennsylvania Department of Environmental Protection for
oil and gas well drilling permits within the field and buffer zone on a semi-annual basis,
available through these agencies websites. The company would use best efforts to monitor
activity under any drilling permit that targets a depth at or below 500 feet above the storage
horizon.
1
(Source: http://www.city-data.com/county/Allegany_County-NY.html).
Page | 2


6.5 Monitoring of Adjacent Production and Storage Operations

Each year, National Fuel reviews gas production records (available through the New York State
Department of Environmental Conservation and Pennsylvania Department of Environmental
Protection) of wells within one (1) mile of the storage buffer boundary that are completed in the
storage horizon. Any well or pool completed in the Oriskany Sandstone that does not exhibit an
expected production decline is designated for evaluation of possible underground connection to
the storage field. National Fuel would request a gas sample from the operator for isotopic
analysis. Also, National Fuel keeps a continuous record of gas volumes and pressures to verify
inventory and detect gas loss. The closest gas storage field is Greenwood Storage,
approximately four (4) miles northeast of the Independence and Beech Hill complex and
operated by Columbia Gas Pipeline a subsidiary of NiSource. If gas loss indications develop,
National Fuel will request and review the operators Annual Underground Natural Gas Storage
Field Report filed with the NYDEC, especially noting gas injected, gas withdrawn, and
operating pressure during each year. The Sharon storage field, operated by Dominion
Transmission, Inc., is approximately five (5) miles southwest of Beech Hill Annex. If gas loss
indications develop, National Fuel would seek to obtain and review inventory and pressure
information on Sharon Storage from the operator or from the FERC.

6.6 Condition of Wells within Proposed Boundaries

Since the beginning of storage operations in the Beech Hill-Independence complex, National
Fuel has had an ongoing program of reworking wells within the storage and buffer to bring them
up to the standards for active or plugged wells set by the New York State Department of
Environmental Conservation or Pennsylvania Department of Environmental Protection. National
Fuel monitors the location of all known wells annually and maintains records of active and
plugged wells in the storage completed to the storage horizon.

6.7 Applicable Drilling Regulations

No well drilling is proposed by this application. National Fuel is not seeking any volume,
pressure, or deliverability changes with this application. The proposed boundary changes will
not affect the ongoing daily operations of the field. No changes will be made in the pattern of
wells used during injection. The single change to the current withdrawal wells will be the
addition of well 7451 as storage gas withdrawal only. Well 7451 will require the addition of a
surface separator and change in surface well piping connections.

Storage well integrity programs, currently in place such as monitoring wellhead pressures at least
monthly, inspecting for gas leaks, and annually inspecting plugged and abandoned wells, will
continue with the same group of wells. Two additional plugged and abandoned wells will be
Page | 3

inspected in the proposed buffer zone. The procedures follow the requirements of the New York
State Department of Environmental Conservation and the Pennsylvania Department of
Environmental Protection. The New York statutory authority is New York Conservation Law
subchapters 70, 73, 74, 75. Natural gas storage is specifically covered in Title 13, subchapter 23-
1301, 1303, 1305, and 1307. Specific sections covering oil and gas well operations are 550
through 559. The Pennsylvania Department of Environmental Protection covers natural gas
storage under Chapter 78 issued under the Oil and Gas Act. Underground Gas Storage is
specifically covered in Subchapter H, Sections 78.401 (Storage well construction), 78.402
(Inspection by the gas storage operator), 78.403 (Gas storage well integrity testing), 78.404
(Maximum storage pressure) 78.405 (Emergency Repairs), 78.406 (Recordkeeping) and, 78.407.
(Plugging gas storage wells).

Page | 4

Map 1
New York
Seismicity Map - 1973 to March 2012

Source:
http://earthquake.usgs.gov/earthquakes/states/new_york/seismicity.php

Independence Beech Hill
Page | 5

Map 2
New York
Seismic Hazard Map

Source:http://earthquake.usgs.gov/earthquakes/states/new_york/hazards.php

Page | 6

Map 3

Source:
http--www.dhses.ny.gov-oem-mitigation-archive-documents-2008-S3.I.ii_Earthquake_Hazard_Profile.pdf.url

Page | 7

RESOURCE REPORT 7 - SOILS
1. Identify, describe, and group by milepost the soils affected by
the proposed pipeline and aboveground facilities.
(380.12 (l)(1))
Not Applicable aside from the de minimus
disturbance associated with a proposed
auxiliary facility described in Resource
Report 1, the application does not
contemplate any proposed earth disturbance
2. For aboveground facilities that would occupy sites over
five acres, determine the acreage of prime farmland soils that
would be affected by construction and operation.
(380.12(i)(2))
3. Describe, by milepost, potential impacts on soils.
(380.12(i)(3) and (4))
4. Identify proposed mitigation to minimize impact on soils, and
compare with the staffs Upland Erosion Control,
Revegetation, and Maintenance Plan. (380.12(i)(5))


RESOURCE REPORT 8 - LAND USE, RECREATION, AND AESTHETICS
1. Classify and quantify land use affect by:
Not Applicable aside from the de
minimus disturbance associated with a
proposed auxiliary facility described in
Resource Report 1, the application does
not contemplate any proposed earth
disturbance.
a) Pipeline construction and permanent rights-of-way; Not Applicable see above
b) Extra work/staging areas; Not Applicable see above
c) Access roads; Not Applicable see above
d) Pipeline and contractor yards; Not Applicable see above
e) Aboveground facilities. Not Applicable see above
2. Identify by milepost all locations where the pipeline right-of-way
would coincide at least partially with existing right-of-way, where
it would be adjacent to existing rights-of-way, and where it would
be outside of existing right-of-way. (380.12(j)(1))
3. Provide detailed typical construction right-of-way cross-section
diagrams showing information such as widths and relative
locations of existing rights-of-way, new permanent right-of-way,
and temporary construction right-of-way. (380.12(j)(1))
4. Summarize the total acreage of land affected by construction and
operation of the Project (380.12(j)(1))
5. Identify by milepost all planned residential or commercial/
business development and the time frame for construction.
(380.12(j)(3))
6. Identify by milepost special land uses (e.g. maple sugar stands,
specialty crops, natural areas, national and state forests,
conservation land, etc. (380.12(j)(4))
7. Identify by beginning milepost and length of crossing all land
administered by federal, state, or local agencies, or private
conservation organizations. (380.12(j)(4))
8. Identify by milepost all natural, recreational, or scenic areas and
all registered natural landmarks crossed by the Project
(380.12(j)(4) and (6))
9. Identify all facilities that would be within designated coastal zone
management areas. Provide a consistency determination or
evidence that a request for consistency determination has been
filed with the appropriate state agency. (380.12(j)(4) and (7))
10. Identify by milepost all residences that would be within 50 feet of
the construction right-of-way or extra work area. (380.12(j)(5))
11. Identify all national or state wild and scenic rivers crossed by the
Project (380.12(j)(6))
12. Describe any measures to visually screen aboveground facilities,
such as compressor stations. (380.12(j)(11))
13. Demonstrate that applications for rights-of-way or other proposed
land use have been or soon would be filed with federal land-
managing agencies with jurisdiction over land that would be
affected by the Project. (380.12(j)(12))


RESOURCE REPORT 9 - AIR AND NOISE QUALITY
Information
Found in
1. Describe existing air quality in the vicinity of the Project.
(380.12(K)(1))
not include any proposed facilities
with air or noise impacts.
2. Quantify the existing noise levels [day-night sound level (L
dn
) and
other applicable noise parameters] at noise-sensitive and at other
areas covered by relevant state and local noise ordinances.
(380.12(k)(2))
3. Quantify existing and proposed emissions of compressor equipment,
plus construction emissions, including nitrogen oxides (NO
x
) and
carbon monoxide (CO), and the basis for these calculations.
Summarize anticipated air quality impacts for the Project.
(380.12(k)(3))
4. Describe the existing and proposed compressor units at each station
where new, additional, or modified compression units are proposed,
including the manufacturer, model number, and horsepower of the
compressor units. For proposed new, additional, or modified
compressor units, include the horsepower, type, and energy source.
(380.12(k)(4))
5. Identify any nearby noise-sensitive area by distance and direction
from the proposed compressor unit building/ enclosure.
(380.12(k)(4))
6. Identify any applicable state or local noise regulations.
(380.12(k)(4))
7. Calculate the noise impact at noise-sensitive areas of the proposed
compressor unit modifications or additions, specifying how the
impact was calculated and include manufacturers data and proposed
noise control equipment. (380.12(k)(4))
8. Include step-by-step supporting calculations or identify the computer
program used to model the noise levels, the input and raw output data,
and all assumptions made when running the model, as well as the
far-field sound level data for maximum facility operations and the
source of the data. (18 CFR 380.12(k)(4)(i))
9. Include sound pressure levels for unmuffled engine inlets and
exhausts, engine casings, and cooling equipment; dynamic insertion
loss for all mufflers; sound transmission loss for all compressor
building components including walls, roof, doors, windows and
ventilation openings; sound attenuation from the station to nearby
noise sensitive areas; the manufacturers name, the model number, the
performance rating; and a description of each noise source and noise
control component to be employed a the proposed compressor station.
For proposed compressors, the initial filing must include at least the
proposed horsepower, type of compression, and energy source for the
compressor. (18 CFR 380.12(k)(4)(ii))
10. Far-field sound level data measured from similar units in service
elsewhere, when available, may be substituted for manufacturers
far-field sound level data. (18 CFR 380.12(k)(4)(iii))


RESOURCE REPORT 10 - ALTERNATIVES
1. Address the no action alternative. (380.12(l)(1))
Not Applicable the application
seeks approval of boundaries
reflecting the actual operational
limits of existing certificated
storage facilities.
2. For large projects, address the effect of energy conservation or energy
alternatives to the Project. (380.12(l)(1))
3. Identify system alternatives considered during the identification of
the Project and provide the rationale for rejecting each alternative.
(380.12(l)(1))
4. Identify major and minor route alternatives considered to avoid
impact to sensitive environmental areas (e.g., wetlands, parks, or
residences) and provide sufficient comparative data to justify the
selection of the proposed route. (380.12(l)(3))
5. Identify alternative sites considered for the location of major new
aboveground facilities and provide sufficient comparative data to
justify the selection of the proposed site. (380.12(l)(3))


RESOURCE REPORT 11 - RELIABILITY AND SAFETY
1. Describe how the Project facilities will be designed, constructed,
operated, and maintained to minimize potential hazard to the public
from the failure of Project components as a result of accidents or
natural catastrophes. (380.12(m))
Not Applicable no certificated
facilities are proposed.


RESOURCE REPORT 12 - PCB CONTAMINATION
1. For projects involving the replacement or abandonment of facilities
determined to have PCBs, provide a statement that activities will
comply with an approved EPA disposal permit or with the
requirements of the TSCA. (380.12(n)(1))
Not Applicable
2. For compressor station modifications on site that have been
determined to have soils contaminated with PCBs, describe the
status of remediation efforts completed to date. (380.12(n)(2))
Not Applicable


RESOURCE REPORT 13 - ADDITIONAL
INFORMATION RELATED TO LNG PLANTS
1. Provide all the listed detailed engineering materials. (380.12(o)) Not Applicable


This information has been removed for privileged and confidential
treatment pursuant to 18 C.F.R. 388.112

EXHIBIT Z-1

GEOLOGICAL REPORT

Included in a separate binder labeled Volume II
PRIVILEGED INFORMATION DO NOT RELEASE

****Matters relating to privileged information should be directed to****

David W. Reitz
6363 Main Street
Telephone No. (716) 857-7949
Facsimile No. (716) 857-7206
reitzd@natfuel.com



EXHIBIT Z-2

GEOLOGICAL MAPS



David W. Reitz
6363 Main Street
Telephone No. (716) 857-7949
Facsimile No. (716) 857-7206
reitzd@natfuel.com



EXHIBIT Z-3

CONTROLLED ACREAGE MAP



David W. Reitz
6363 Main Street
Telephone No. (716) 857-7949
Facsimile No. (716) 857-7206
reitzd@natfuel.com



EXHIBIT Z-4

AFFECTED PROPERTY OWNERS



David W. Reitz
6363 Main Street
Telephone No. (716) 857-7949
Facsimile No. (716) 857-7206
reitzd@natfuel.com

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Trans Letter_Beech Hill-2014.PDF......................................1-2
FINAL_Application-Beech Hill-Independence 2014.PDF....................3-74

Application 20140613-5205 (29485149)

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