Rover Pipeline LLC is urging FERC to stay the course and reauthorize work on its Mainline B horizontal directional drill (HDD) under the Tuscarawas River in Ohio, with the company indicating it's "frustrated by the inaccurate central premise" behind the directive it issued last week.
Rover, in a letter Sunday to the Federal Energy Regulatory Commission's Office Energy Projects Director Terry Turpin, said the Commission "fully expected the loss of drilling fluids" during the HDD when it approved both its original certificate and revised plans developed in response to an inadvertent return that occurred during the Mainline A crossing of the Tuscarawas last year.
The plans developed for the Mainline B Tuscarawas HDD -- approved by FERC with guidance from two different third party engineering experts -- "explicitly contemplate 'complete or significantly diminished circulation loss that cannot be restored during the HDD,’” and include measures to respond to any loss of fluids to minimize impacts, Rover said.
"And, most relevant here, the responses set forth in the plans when returns are lost do not call upon Rover to halt the drill and stop construction," Rover wrote. "Instead, as approved by the Commission, the plans affirm that as currently designed, the Tuscarawas River Mainline B HDD has a lower risk of an inadvertent release occurring within" a nearby wetland since the revised path "is approximately 100 feet deeper than Mainline A and crosses consolidated rock for a longer length of the HDD."
Rover said it has had environmental inspectors on site day and night during drilling, in addition to thermal imaging cameras and two drones monitoring the right of way and surrounding area. Rover has also taken steps to prevent fluid losses and has stopped work as needed “to manage loss of circulation,” the company said.
Last week, FERC ordered Rover to halt progress on its second HDD beneath the Tuscarawas River due to a reported loss of drilling fluids, though no inadvertent returns had been documented. FERC asked the operator to evaluate next steps, including possible alternatives.
An alternative crossing method FERC contemplated in its order wouldn't be ideal due to a host of logistical complications, according to Rover. Meanwhile, an alternative route could potentially increase -- rather than minimize -- impacts, the company said.
With Mainline B sharing the same workspace as the completed Mainline A, the impacts from an alternative route "would be cumulative to the impacts already incurred during the installation of Mainline A, and the Mainline B pipeline approaches up to the HDD entry and exit locations," according to Rover.
The operator urged the Commission to "authorize Rover to complete this pipeline as certificated and to authorize Rover to recommence with the Tuscarawas River HDD immediately."
The 3.25 Bcf/d, 713-mile Rover, designed to deliver Marcellus and Utica shale gas to markets in the Midwest, Gulf Coast and Canada, has already seen significant delays since starting construction last year, largely due to FERC's suspension of HDD activities following the inadvertent return during the Tuscarawas HDD.
Rover has been flowing around 1.4 Bcf/d from eastern Ohio to interconnects with the ANR and Panhandle Eastern pipelines in Defiance, OH, according to NGI’s daily Rover Tracker.
The project is nearing completion and is scheduled to enter full service by the end of March, backer Energy Transfer Partners LP has said, though analysts have pointed to the risk for further delays resulting from FERC's most recent action.
"We cannot predict whether good intentions and diligent good practice will necessarily offset stubbornly inhospitable geological conditions," ClearView Energy Partners LLC told clients last week. "We would not rule out a multi-month delay to the completion of Mainline B if FERC finds it appropriate to direct Rover to use a new route across the Tuscarawas because the current crossing location presents unacceptable adverse environmental impact."
Genscape Inc. noted that "the Tuscarawas HDD is a particularly problematic drill as it is lengthy (in footage and time needed to drill) and located near sensitive resources. In addition, it has attracted extra scrutiny from regulators" after the inadvertent return last year.
"Any significant delays in obtaining permission to resume drilling will generate an associated delay for Rover's Phase 2 in-service date," the firm said.