EPNG is hereby submitting formal responses to the questions that were part of the Data Request, including the referenced attachments.

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1 August 17, 2018 Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C Attention: Ms. Kimberly D. Bose, Secretary Re: El Paso Natural Gas Company, L.L.C.; Docket No. CP Responses to Data Request OEP/DPC/CB-2 Dear Ms. Bose: On August 7, 2018, El Paso Natural Gas Company, L.L.C. ("EPNG") received a data request ( Data Request ) from the Office of Energy Projects Regulation ( OEP ) seeking information on the. Accordingly, EPNG is herein filing with the Federal Energy Regulatory Commission ("Commission") its response to the Data Request. Description of Proceeding On April 27, 2018, EPNG submitted its application, pursuant to Section 7(c) of the Natural Gas Act requesting a certificate of public convenience and necessity for authorization to construct, own, and operate: 1) an approximate 17-mile 30 diameter loop line of its existing Line Nos and 1103 between Hueco and El Paso, Texas; 2) the new Red Mountain Compressor Station in Luna County, New Mexico; and 3) the new Dragoon Compressor Station located in Cochise County, Arizona. This project is referred to as the. Description of Information Being Filed EPNG is hereby submitting formal responses to the questions that were part of the Data Request, including the referenced attachments. Filing Information EPNG is e-filing this letter and responses with the Commission's Secretary in accordance with the Commission's Order No. 703, Filing Via the Internet, guidelines issued on November 15, 2007 in Docket No. RM As part of this filing, EPNG is including revised system flow diagrams labeled CONTAINS CUI//CEII DO NOT RELEASE and the corresponding electronic Synergi

2 Federal Energy Regulatory Commission -2- August 17, 2018 pipeline hydraulic flow model files. The system flow diagrams and the electronic Synergi pipeline hydraulic flow model files being filed under this section meets the definition of CEII as found in Section of the Commission s regulations and therefore EPNG requests that the Commission accord treatment to the flow diagrams and files concerning CEII information in a manner consistent with Sections and of the Commission s regulations for the life of the assets so as not to place the assets and personnel of EPNG at undue risk. If you have any questions regarding this request for CEII treatment, please contact Mr. Francisco Tarin at or via at Francisco_Tarin@kindermorgan.com. Respectfully submitted, EL PASO NATURAL GAS COMPANY, L.L.C. By /s/ Francisco Tarin Director, Regulatory Enclosures

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4 1. As part of its application, EPNG filed four flow diagrams, two existing (summer and winter) and two proposed (summer and winter), in order to support its proposed. In each of the flow diagrams EPNG aggregates the sum of the receipts and deliveries between each compressor station in order to maximize gas flow through these pipeline segments between compressor stations. a. Explain how the aggregation of gas flows accurately represents the system s operational flowing capacity along the South Mainline System operating during each of the four peak day flow scenarios. b. How does the aggregation of gas flows accurately represent system operating conditions for the purpose of designing facility modifications in lieu of using actual receipt and delivery point locations along EPNG's mainline? a. The flow diagrams associated with the are constructed to show the physical demands upon transmission system capacity before and after the installation of the proposed facilities. To replicate the physical demands upon the system, contractual commitments must be described in terms of the capacity to which shippers are contractually entitled. Shippers often aggregate their nominations by using receipt pools for receipt quantities and/or D-codes for delivery quantities. To prudently account for the capacity required to transport quantities from receipt pools to D-codes, receipt quantities are loaded at the furthest upstream location on a segment and D-codes are loaded at the furthest downstream location on a segment. In so doing, EPNG accurately models the maximum transport capacity to which shippers are contractually entitled, and eliminates the potential for over-contracting and over-scheduling the pipeline. b. When designing facility modifications, all transportation capacity to which shippers are contractually entitled must be factored into EPNG s analysis. Since aggregations such as receipt pools and D-codes are included in transportation agreements, and nominated and scheduled every day, capacity utilization must be modeled in a manner consistent with these aggregations. By modeling these aggregations as described in its response to 1.a., EPNG accurately assesses and evaluates all of the capacity entitlements across its system.

5 2. Provide new flow diagrams and corresponding engineering flow models (using DNV GL s Synergi pipeline hydraulic modeling software) that show the location of each receipt and delivery point for this project, with corresponding receipts and deliveries that will utilize both the existing capacity and the proposed new capacity on the South Mainline System in order to provide the proposed service for both the existing (design summer and winter) and proposed (summer and winter). As part of EPNG s response, differentiate between the existing and new capacity. EPNG has included under the Critical Energy Infrastructure Information section of this response four diagrams and the corresponding engineering flow model files with the requested location of each receipt and delivery location and the corresponding receipts and deliveries that will utilize both the existing capacity and the proposed new capacity on the South Mainline System for this project (modeled using DNV GL s Synergi modeling software). Figures 1, 2, 3 and 4 correspond to Figures 1, 2, 3 and 4 filed in the Exhibit G from EPNG s original application. Additionally, Figures 3 and 4 incorporate tables summarizing the capacity created by the South Mainline Expansion from Cornudas A Plant to DSNJQUIN on EPNG s Line No System. These tables also summarize the capacity, on a segment by segment basis, created in the summer (August) and winter seasons (January). As noted in the tables, the capacity created by the from Cornudas A Plant to DSNJQUIN is MMscf per day (equal to 203,546 Dth per day) in the summer (August) and MMscf per day (equal to 167,984 Dth per day) in the winter (January).

6 3. Explain how EPNG will make the use of expansion capacity versus existing capacity within each path or zone that will make up the new proposed service. Demonstrate the use of each capacity through the use of flow schematics. The schematics provided in the original filing, along with the diagrams provided in response to Question 2 of this data request, support and demonstrate the need for (and use of) the expansion facilities necessary to provide the maximum primary firm contracted quantities and locations. Expansion designs are aimed at relieving the most binding system constraints that prevent the requested service. EPNG routinely evaluates whether requests for capacity can be accommodated, in whole or in part, via a more efficient handling of existing facilities. From a day to day operational perspective, EPNG makes no distinction between existing and expansion capacity. Transportation capacity and the facilities that are utilized to create it are viewed in the aggregate. On any given day, nominations rarely, if ever, conform entirely to maximum primary firm contracted quantities and locations. All transmission system facilities, expansion and existing, are optimized to provide the maximum level of service possible to shippers, and to do so efficiently. Given the reticulated nature of the EPNG system, multiple flow paths are assessed and utilized to provide for as much aggregated transport demand as the shippers request or the system will allow. Thus, in an instance (like the South Mainline Expansion) where the requested capacity requires the installation of facilities that will integrate into the existing system, the use of the newly requested capacity may flow through the use of facilities existing prior to the expansion while correspondingly, the use of capacity existing prior to the expansion may flow through the use of the expansion facilities.

7 4. What is the maximum design utilization rate for each of EPNG s compressor stations located on the South Mainline System which are currently used to determine pipeline capacity between each compressor station? Explain any differences between stations. The maximum design utilization for EPNG s compressor stations is shown in the tables included on the previously provided flow schematics labeled on the row titled BHP Utilization at Site. The BHP Utilization at Site for each compressor station is a function of the pipeline capacity, as defined by the maximum and minimum pressure limits of the upstream and downstream pipeline segments. Additionally, design factors associated with the actual compressors (i.e., maximum speed limits, surge protection limits for centrifugal compressors and clearance volume limits for reciprocating compressors), as well as the other ancillary systems (e.g., the availability of gas cooling equipment) will limit the BHP Utilization at Site.

8 5. What is the maximum design utilization rate for EPNG s compressor stations that is currently used to determine pipeline capacity between each compressor station? Refer to EPNG s response to Request No. 4.

9 Certificate of Service I hereby certify that I have this day caused a copy of the foregoing documents to be served upon each person designated on the official service list compiled by the Commission's Secretary in this proceeding in accordance with the requirements of Section of the Federal Energy Regulatory Commission's Rules of Practice and Procedure. Dated at Colorado Springs, Colorado as of this 17 th day of August, /s/ Francisco Tarin Two North Nevada Avenue Colorado Springs, Colorado (719)