**MID-ATLANTIC EXPRESS LLC**

**MID-ATLANTIC EXPRESS PIPELINE PROJECT**

**Horizontal Directional Drill Monitoring and Contingency Plan**

**January 2007**

**TABLE OF CONTENTS**

Page

I. introduction [1](#introduction)

1.01 Purpose and Scope [1](#purpose-and-scope)

II\. hdd installation process AND segment alignments
[3](#hdd-installation-process-and-segment-alignments)

2.01 HDD Installation Process [3](#hdd-installation-process)

2.02 HDD Segment Alignments [8](#hdd-segment-alignments)

A. Mid-Atlantic Express Pipeline Route
[8](#mid-atlantic-express-pipeline-route)

B. Proposed HDD Locations [9](#proposed-hdd-locations)

III\. HDD Monitoring program [14](#hdd-monitoring-program)

3.01 General [14](#general)

3.02 Monitoring Responsibilities of the Environmental Inspectors
[14](#monitoring-responsibilities-of-the-environmental-inspectors)

3.03 Monitoring of HDD Segments [14](#monitoring-of-hdd-segments)

IV\. contingency PLAN and Corrective Actions
[16](#contingency-plan-and-corrective-actions)

4.01 General [16](#general-1)

4.02 Drilling Fluid Releases [17](#drilling-fluid-releases)

A. HDD Land Segments [17](#hdd-land-segments)

4.03 Equipment Failure [17](#equipment-failure)

V. Abandonment [19](#abandonment)

VI\. Notification and Reporting Procedures
[20](#notification-and-reporting-procedures)

6.01 Notifications [20](#notifications)

6.02 Reporting [20](#reporting)

**ATTACHMENTS**

**Attachment A** **-- Proposed Susquehanna HDD Crossing Layout**

**Attachment B** **-- Proposed Back River HDD Crossing Layout**

# introduction

## Purpose and Scope

AES Sparrows Point LNG, LLC (Sparrows Point LNG) proposes to construct,
own, and operate a new liquefied natural gas (LNG) import, storage, and
regasification terminal (LNG Terminal) at the Sparrows Point Industrial
Complex situated on the Sparrows Point peninsula east of the Port of
Baltimore in Maryland. LNG will be delivered to the LNG Terminal via LNG
marine traffic, offloaded from these ships to shoreside storage tanks,
regasified on the LNG Terminal site (Terminal Site), and transported to
consumers via pipeline. The LNG Terminal will have a regasification
capacity of 1.5 billion standard cubic feet of natural gas per day
(bscfd), with potential to expand to 2.25 bscfd. Regasified natural gas
will be delivered to markets in the Mid-Atlantic Region and northern
portions of the South Atlantic Region, through an approximately 88-mile,
30-inch outside diameter natural gas pipeline (Pipeline) to be
constructed and operated by Mid-Atlantic Express, LLC (Mid-Atlantic
Express). The Pipeline will extend from the LNG Terminal to
interconnections with existing natural gas pipeline systems near Eagle,
Pennsylvania. Together, the LNG Terminal and Pipeline projects are
referred to as the Sparrows Point Project or Project. Both Sparrows
Point LNG and Mid-Atlantic Express (hereinafter collectively referred to
as AES) are subsidiaries of The AES Corporation.

The Project footprint is located in the counties of Baltimore, Harford
and Cecil in Maryland, and in the counties of Lancaster and Chester in
Pennsylvania. The Terminal Site, which is located entirely within
Baltimore County, is a parcel located within a former shipyard. The
route proposed for the Pipeline (Pipeline Route), which crosses all of
the listed counties, includes industrial, commercial, agricultural, and
residential lands. Together, the Terminal Site and the Pipeline Route
comprise the Project Area.

The pipeline will cross 177 water bodies as identified during field
reconnaissance, including perennial, intermittent and ephemeral streams,
using one of the crossing methods described in Resource Report 2, *Water
Use and Quality*. The crossing method selected will be the method that
provides the least disturbance and most expedient crossing to minimize
overall impact. Crossing methods for each of the water bodies are
indicated on Table 2.4-1 of Resource Report 2, *Water Use and Quality*.

Specific crossings are planned as horizontal directional drill (HDD)
crossings; however, specific geotechnical design investigations and
engineering reviews are needed to assess feasibility of such HDD
crossings. In addition, the National Marine Fisheries Service has
requested evaluation of HDD crossing at limited additional locations
(e.g., Gunpowder Falls, Deer Creek, and the Octoraro River). The
investigations of Back River and the Susquehanna, as well as evaluation
of HDD crossing at the remaining locations, are further described below.

The HDD technique is an established trenchless technology that is
commonly used to install pipelines and other buried utilities with
minimum environmental and construction-related impacts. This HDD
Monitoring and Contingency Plan establishes specific procedures for
monitoring HDD operations in order to minimize potential environmental
impacts, such as impacts from unexpected releases of drilling fluid
(bentonite slurry) for various waterbody and land crossings during
construction of the Project.

This HDD Monitoring and Contingency Plan includes a description of the
following:

-   HDD Overview;

-   Monitoring;

-   Contingency Plan and Corrective Actions;

-   Abandonment;

-   Notification procedures.

# hdd installation process AND segment alignments

## HDD Installation Process

HDD involves drilling a continuous borehole beneath surface obstacles,
and then pulling pipeline or other utility components through the
underground borehole, leaving the surface undisturbed. HDD construction
methods generally includes three stages: pilot hole directional drill,
reaming of the pilot hole and pull back of the pipe materials through
the reamed drill hole. The HDD installation design will be included in
the Project design. Site specific conditions for each HDD segment will
be incorporated from the geotechnical design investigation program.

The HDD pilot hole directional control is achieved by using a
non-rotating drill string with an asymmetrical leading edge. Figure 2-1
presents the typical pilot hole drilling process. The asymmetry of the
edge creates a steering bias, while the non-rotating aspect of the drill
string allows the steering bias to be held in a specific position during
advancement. If a directional heading change is required, the drill
string is rotated such that the direction of the steering bias is the
same as the desired directional change. The direction of this bias is
referred to as the tool face. Advancement in a straight direction
without directional bias is achieved by a series of offsetting tool face
positions. The drill string may also be continually rotated where
directional bias is not required. Leading edge asymmetry can be
accomplished by several methods, such as an angular offset built into
the tool face.

**Figure 2-1**

**Typical Pilot Hole Drilling**

![](media/image1.png){width="5.845833333333333in" height="1.90625in"}

Other equipment or techniques utilized for creating directional control
during HDD include jetting head (commonly utilized in soft soils) or
downhole motors. The HDD directional control for other methods is
generally the same as using an asymmetrical leading edge tool face with
a non-rotating drill string. Control of the steering bias for the HDD
equipment is performed by adjustments (rotation) of the drill string. In
some instances, a wash pipe may be utilized, rotating concentrically
over the non-rotating drill string. A wash pipe prevents sticking of the
steerable string, allows the tool face to be oriented freely and allows
stabilization of the pilot hole in case it becomes necessary to remove
the drill string.

The path of the HDD pilot hole is monitored during drilling by
collecting periodic measurements of the inclination and azimuth of the
leading edge. These measurements are collected with an instrument probe
inserted at the drill collar, as close as possible to the tool face, and
connected to surface monitoring equipment by a wire within the drill
string (the combination of the tool face, mud motor, survey probe,
non-magnetic collar and other leading edge equipment is referred to as
the bottom hole assembly). These readings and calculated linear
measurements of the drill string are utilized to calculate the
horizontal and vertical coordinates along the pilot hole. Azimuth
readings are collected from the earth's magnetic field and may be
subject to interference from downhole drill tools, drill string pipe,
wash pipe or magnetic fields created by adjacent structures. Therefore,
the probe must be inserted in a non-magnetic collar and positioned in
the drill string to isolate from downhole tools and pipe.

Additionally, the pilot hole may be monitored using a surface monitoring
system. Surface monitoring systems determine the location of probe
downhole by collecting measurements from a grid or points at the
surface. These systems utilize a surface coil of known location to
induce a magnetic field. Measurements are collected from the surface as
the probe senses its location relative to the induced magnetic field.

The pilot hole is reamed to larger diameter using reaming tools, which
typically consist of a circular array of cutters and drilling fluid
jets, as shown in Figure 2-2. Reaming may be performed by attaching a
reaming tool to the drill string at the exit location and drawing the
tools back to the drill rig. Drill pipe is added behind the pre-reaming
tools to ensure a string of pipe is always maintained in the drill hole.
Reaming may also be performed from the drill entry point, thrusting the
reaming tools from the drill rig towards the exit point.

**Figure 2-2**

**Typical Reaming Process**

![](media/image2.png){width="5.707638888888889in"
height="1.8958333333333333in"}

Upon completion of reaming the drill hole to necessary diameter, pipe
installation is accomplished by attaching prefabricated pipeline
materials behind the reaming assembly at the drill exit location and
pulling the assembly back through the drilled hole. A swivel is utilized
to connect the pull pipe section to the reaming assembly to minimize
torsion transmitted to the pipe as shown in Figure 2-3.

**Figure 2-3**

**Typical Pullback Process**

![](media/image3.png){width="5.65625in" height="1.90625in"}

The drill cuttings generated from the drilling operations will be
stockpiled in water-tight containers at locations in the uplands in a
manner that prevents their release into the water or surrounding area.
At the completion of the drilling operations, remaining materials shall
be dried at an upland location either on-site or off-site, and then
transported to an authorized upland landfill for disposal. No discharge
of water or drill cuttings to waters of the State will be allowed during
stock piling, drying, and transportation. Copies of the authorized
landfill disposal receipts will be submitted to FERC and local
regulatory agencies, as required.

The method can have other off-setting impacts at the construction area
around the feature being crossed. However, these off-setting impacts are
typically temporary. During HDD operations, fluid pressures can build up
within the borehole, potentially resulting in hydraulic fracturing and
subsequent migration of drilling fluids to the surface defined as
"frac-out". Potential off-setting impacts include the greater area
required for set-up and operations at both ends of the drill hole; the
round-the-clock operation of the drill rig during construction of the
crossing and associated noise; and the potential for frac-out of the
drilling fluid. The two primary factors affecting hydraulic fracturing
in soil are borehole pressure and depth of cover. When the pressure in
the borehole exceeds the strength of the surrounding strata, a potential
frac-out condition occurs. Based on these potential off-setting factors,
the use of HDD for these specific crossings will continue to be
evaluated against possible other crossing techniques.

Prior to the final design of the plan and profile drawings and the start
of construction, soil core samples will be taken on both sides of the
crossing and selected locations along the crossing to evaluate rock,
sand, or soil conditions. Following the analysis of the subsurface
conditions, the drill site will be surveyed to determine and stake the
drilling entrance and exit points. A final drill plan and profile
drawing will then be generated to accurately define the operation. The
profile drawing will establish the entrance and exit angles, the maximum
depth of the pipe, and the minimum radius of curvature to avoid
overstressing the pipe, and the length of the pull.

During the drilling, reaming, and pullback process, the contractor will
maintain control of the drilling mud to make sure that no drilling mud
enters the waterbody, any tributaries, or stream beds. The contractor
will provide all onsite materials and equipment required to contain and
clean up drilling mud releases and will have full time qualified
personnel on site cleanup any accidental releases of drilling mud as
further described in Section V. Additionally, in order to avoid spills
of fuels, lubricants and other materials the construction contractor
will operate in accordance with the MAE Spill Prevention Control and
Countermeasures Plan. Restoration and Revegetation will be conducted in
accordance with the MAE Environmental Construction Plan. These documents
are included as Appendix 2C and Appendix 2A, respectively, of Resource
Report 2, *Water Use and Quality*.

The drill rig side will typically require a workspace of approximately
150 ft. x 150 ft and will contain the following equipment as shown in
Figure 2-4:

-   Drilling rig unit

-   Power generation unit

-   Drilling pipe storage

-   Water pump and water piping

-   Bentonite storage

-   Slurry mixing tank

-   Slurry pump

-   Drill cuttings separation equipment

-   Entry point slurry containment pit

-   Cuttings settlement pit

-   Offices and storage

A work space of approximately 150ft. x 150 ft. is typically necessary at
the exit point for the equipment listed below:

-   Cuttings settlement pit

-   Exit point slurry containment pit

-   Drill pipe storage

-   Miscellaneous equipment and storage

An additional work space of 50 ft. wide x the lengths of each pipe
section is required for the following:

-   30" pipe sections)

-   Pipe rollers

> **Figure 2-4**
>
> **Typical HDD Entry Site Layout**
>
> ![](media/image4.png){width="4.9375in" height="3.0625in"}

The pipe size to be installed in the bore is 30" OD. The pipe will have
FBE fusion bond epoxy (FBE) coating, DFT 20 mil. Because of the
potential exposure to solid rock, the pipe will have an additional
coating of epoxy based polymer concrete as required, DFT 40 mils
thickness. Girth welds at field joints will be coated with FBE powder,
minimum 25 mil thickness.

## HDD Segment Alignments

### Mid-Atlantic Express Pipeline Route

The Pipeline will extend from the LNG Terminal to proposed
interconnections with the existing Columbia Gas Transmission Corporation
("Columbia"), Transcontinental Gas Pipe Line Corporation ("Transco") and
Texas Eastern Transmission Corporation ("TETCO") interstate pipeline
systems near Eagle, Pennsylvania. The proposed Pipeline Route generally
parallels existing ROW for highways, overhead electric transmission
lines and pipelines. More specifically it:

-   Exits the former Sparrows Point Shipyard and steel mill property,
    north to northeast, for approximately 2 miles (MP 0.0 to 2.0);

-   Follows Route I-695 with the exception of minor divergences (to
    avoid interchanges) north and northwest for approximately 6 miles
    (MP 2.0 to 8.0);

-   Near the Back Creek crossing, turns north to northeast and follows a
    BG&E overhead transmission corridor for approximately 24.5 miles (MP
    8.0 to 32.5); and

-   At an intersection with the right-of-way for an existing Columbia
    pipeline, turns northeast and generally parallels the existing
    pipeline corridor for approximately 54 miles (MP 32.5 to 87.6) to
    its terminus near Eagle, Pennsylvania.

### Proposed HDD Locations

MAE has evaluated selected critical water bodies for crossing using the
HDD method, consistent with the request by National Marine Fisheries
Service (NMFS), including:

-   Back River

-   Gunpowder Falls

-   Deer Creek

-   Susquehanna River

-   Octoraro River

In each case, use of the HDD method provides potential advantages to
crossing the water bodies for the following reasons:

-   It is the method most likely to have no impact on water quality or
    flow during construction.

-   It offers the maximum depth of cover under obstacles thereby
    offering greater protection over the Pipeline than other typical
    crossing methods.

-   It does not disturb surface features (vegetation, stream banks,
    etc.) during or after construction.

Currently, MAE believes that the HDD crossing method is the appropriate
method to be used for the Back River and Susquehanna River crossings.
MAE believes that the Gunpowder Falls, Deer Creek and Octoraro River
crossings can be performed utilizing other techniques as described in
Resource Report 2, *Water Use and Quality*.

It is estimated that the horizontal distances for each of the
directional crossings will be as listed in Table 2-1 from an entry point
on one bank to an exit point on the other bank. The drilling rig spread
will be located on the one bank and the pipe fabrication and pullback
spread will be located on the other bank. The contractor will provide
Bentonite clay mixed with water for the drilling fluid and will mobilize
the drilling equipment, erect the drilling rig, drill the hole, ream the
hole as necessary, and pullback the pre-fabricated pipe section in the
proposed horizontal drilled crossing. As the drilling operation
progresses, the contractor will be continuously plotting the actual pipe
profile against the proposed pipe profile to ensure cover requirements
and target exit points will be achieved

**Table 2-1**

**Proposed HDD Crossings**

  ---------------- ----------- ------------- ------------------ -------------- --------------
  Water Crossing   Waterbody                 Waterbody Crossing Approximate    Pipe Laydown
                   Width at                  Classification     HDD Distance   Length
                   Crossing                                                    

  **Susquehanna    **3200                    **Major**          **5120 ft**    **2600 ft**
  River**          ft.**                                                       

  **Back River**   **TBD**                   **Intermediate**   **1056 ft**    **1300 ft**

                                                                               

  Note:                                                                        

  \"Minor                      includes                                        
  Waterbody\"                  waterbodies                                     
                               less than or                                    
                               equal to 10                                     
                               feet wide at                                    
                               the water\'s                                    
                               edge at the                                     
                               time of                                         
                               crossing.                                       

  \"Intermediate               includes                                        
  Waterbody\"                  waterbodies                                     
                               greater than                                    
                               10 feet wide                                    
                               but less than                                   
                               100 feet wide                                   
                               at the                                          
                               water\'s edge                                   
                               at the time                                     
                               of crossing.                                    

  \"Major                      includes                                        
  Waterbody\"                  waterbodies                                     
                               greater than                                    
                               100 feet wide                                   
                               at the                                          
                               water\'s edge                                   
                               at the time                                     
                               of crossing.                                    

  TBD                          Indicates                                       
                               exact width                                     
                               at crossing                                     
                               to be                                           
                               determined                                      
                               during                                          
                               engineering                                     
                               survey                                          
  ---------------- ----------- ------------- ------------------ -------------- --------------

**B.1. Susquehanna River Crossing**

**B.1.a Susquehanna River preferred crossing method:**

At the Susquehanna River, due to a lack of workspace on the pullback
(east) side it will be necessary for at least two pipe sections of
approximately 2,560 feet in length each to be pre-fabricated and pulled.
These pre-fabricated pipe sections will be welded, 100% x-ray inspected,
weld repairs performed as required, field joints coated, and the pipe
section shall be hydrostatically tested prior to pulling. The first pipe
section will then be pulled into the bore hole. High volumes of drilling
mud will be continuously circulated after pulling is terminated and then
the second pre-fabricated pipe section will be welded to the tail end of
the first pipe section, x-rayed, and field joint coating applied. Total
estimated time for welding, welding inspection, and field joint coating
will take approximately 4 hours. Drilling mud will then be continuously
recirculated until the second pipe section has been pulled.

The Susquehanna River Crossing represents one of two major water body
crossings (i.e. crossing width greater than 100 feet). As such MAE has
developed a contingency crossing plan as described below. Site specific
drawings showing the proposed HDD alignment, work areas, and additional
temporary workspaces for the HDD Crossings are included as Attachment A.
MAE will provide copies of local permits received for the HDD at the
Susquehanna River when they are received.

**B.1.b Susquehanna Crossing Contingency Plan**

If a pipeline crossing of the Susquehanna River is not feasible using
the horizontal directional drill method, an alternate method of crossing
the river must be selected. As an alternate the pipeline will be laid in
the river bottom. The river, at the point of crossing, is approximately
3,200 feet wide. The river is approximately 70 feet deep with a solid
rock bottom covered with large boulders. The rock bottom is covered with
a layer of soft silt deposits varying in thickness from 10 to 25 feet.

The proposed 30-inch pipeline crossing will be placed on crushed stone
supports spaced across the river bottom approximately 80 feet apart. The
crushed stone will be placed on the riverbed through a series of
controlled pours through a fall pipe from a barge into forms set on the
riverbed. The crushed stone will allowed to settle through the silt
deposits to the rock bottom. The crushed stone will settle to the rock
bottom and form a support structure at the desired level to provide
support for the pipeline. Each support will be approximately 5 feet by
15 feet. Approximately 10,000 cu. yds. of crushed stone will be used to
create these supports. An additional 1,000 cu. yds. of crushed stone
will be placed by the same process to provide a minimum of 2 foot
coverage over the pipe which will be used as cover for pipeline
protection and for shoreline stabilization.

Pipeline construction on the banks approaching the river will be by the
conventional method and will require new right-of-way. Approximately 2
acres of trees on both banks will be cleared to create the 75 foot
construction right-of-way. An additional 2 acres of trees will be
cleared to create the staging area for the river crossing operation. MAE
will perform construction activities in accordance with the
Environmental Construction Plan included as Appendix 2A to Resource
Report 2, *Water Use and Quality* which is based on FERC's Wetland and
Waterbody Construction and Mitigation Procedures (January 17, 2003
Version), and consultations with the MDE, PDEP, MDNR, Susquehanna River
Basin Commission, as well as county conservationists in both
Pennsylvania and Maryland, in order to address local concerns and
practices regarding erosion and sediment control in the plan. The
right-of-way will be maintained at 50 feet following construction. Some
grading may be required to create the staging area. Following
construction the area will be restored in accordance with the
Environmental Construction Plan included as Appendix 2A to Resource
Report 2, *Water Use and Quality*. Construction operations will be
conducted in accordance with the requirements of the MAE Spill
Prevention, Countermeasures and Control (SPCC) Plan, included as
Appendix 2C to Resource Report 2, *Water Use and Quality*, which
describes the measures to be implemented to avoid or minimize the
potential for significant leaks or spills of petroleum products or other
hazardous materials that may occur in the Project Area.

Concrete coated pipe will be welded together in the staging area and the
fabricated pipeline string will be floated onto the river. Once the
pipeline has been extended to reach the opposite shore it will be
lowered in a controlled manner to rest over the crushed stone supports.
The pipeline is 30" OD, 1.125"wt pipe with 2" of concrete coating and
has a negative buoyancy. As the pipe is reeled off the barge it will
naturally sink to the bottom displacing silt and come to rest on the
gravel supports. Because of the negative buoyancy there will be no need
to flood the pipe.

Pipeline construction on the east bank will require the installation of
a conventional bore beneath the railroad track and Manor road. A bore
pit will be required on both sides of the railroad and Manor road. The
bore pit on the east side will have to be shored. The west side bore pit
will require the placement of a steel structured caisson. Estimated
caisson size is approximately 50 feet x 125 feet length. Estimate length
of the bore is 200 feet. The bore pipe consists of FBE coated and
concrete coated pipe welded together in the staging area on the east
bank. After the water is pumped out of the new constructed caisson and
discharged in accordance with applicable project permits, a crane will
lower a conventional boring machine into the caisson (west bore pit).
Cranes will be used to lower pipeline construction equipment into the
east bore pit. The bore operation will be from west to east and the pipe
will be pulled from the east to west. Welded tie-ins will be made to
tie-in the installed bore pipe to the river pipe and land pipe. The
construction of the entire Susquehanna River crossing will require
approximately 100 personnel and 6 months to complete.

The contractor will have warning vessels upstream and downstream of
construction activity and communications set up with the appropriate
regulatory agencies during construction to regulate river traffic.

**B.2. Back River Crossing:**

**B.2.a. Back River Preferred Crossing Method:**

The preferred crossing method for Back River is by HDD. At Back River,
the pullback side of the HDD will have one pipe section of approximately
1056 feet in length to be pre-fabricated, tested and pulled. This pipe
section will be welded, 100% x-ray inspected, weld repairs performed as
required, field joints shall then be coated, and the pipe section shall
be hydrostatically tested prior to pulling. Drilling mud will then be
continuously recirculated until the pipe section has been pulled. Site
specific drawings showing the proposed HDD alignment, work areas, and
additional temporary workspaces for the HDD Crossings are included as
Attachment B. MAE will provide copies of local permits received for the
HDD at the Back River when they are received.

**B.2.b. Back River Crossing Contingency Plan:**

If a pipeline crossing of Back River is not feasible using the
horizontal directional drill method, an alternate method of crossing the
river must be selected. As an alternate the pipeline will be laid in the
river bottom. The ditch for the pipe will be dredged using a bucket type
excavator located on a barge. The dredge spoil will be disposed of by
redepositing the soil in the trench over the pipe. It is estimated that
approximately 530 cu. yds. of material will be removed for the entire
ditchline.

Following the dredging process the pipe will be laid in the new ditch. A
pipe lay barge will follow the dredge to lower pipe into the ditch
immediately following excavation. The pipe will be welded,
radiographically inspected, and each field joint coated on the barge
prior to lowering into the water. Estimated construction progress is 400
-- 500 ft./ 24 hour day. All pipe joints will be FBE coated and concrete
coated for additional weight. Field joints shall be FBE coated.

Once the soils are placed back over the installed pipe, no further
mechanical movement of the spoil in the ditch is needed following the
pipe lay. The ditch will smooth and close up naturally due to river
currents.

For safety purposes, the contractor will have warning vessels upstream
and downstream of construction activity and communications set up with
the appropriate regulatory agencies during construction to monitor and
regulate river traffic in the area of the crossing.

#  HDD Monitoring program

## General

Monitoring for potential drilling fluid release or frac-out will occur
throughout the HDD processes to ensure that any potential impacts to the
environment is avoided and/or minimized.

## Monitoring Responsibilities of the Environmental Inspectors

The responsibilities of the Environmental Inspectors relative to
monitoring the HDD operations will be:

-   Monitor for evidence of other potential environmental impacts;

-   Monitor pipestring assembly and pull-back operations;

-   Monitor the demobilization of drilling equipment; and,

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-   Ensure Contractor compliance with Project Permits.

Environmental Inspectors will also oversee the transfer of the drill
cuttings, circulation fluids and any other wastes generated during HDD
operations to an appropriate vehicle for transportation to an authorized
upland disposal site.

Environmental Inspectors will monitor all phases of the HDD process to
ensure adherence to the Project environmental plans and to identify and
respond appropriately to any incidences of drilling fluid frac-out.

The monitoring program for the HDD Segments is described below.

## Monitoring of HDD Segments

The drilling operations for the HDD crossings along the route will
include the three locations described above. Monitoring procedures
during drilling operations will include:

-   Continuous examination of drilling fluid pressures and return flows;

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-   Inspection along the drill path by an Environmental Inspector from
    roadways and developed land where appropriate and on foot or from a
    small boat for water crossings.

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-   If a frac-out is detected during wetland or water crossings, the
    drill operators will perform the contingency measures as described
    below in Section IV. (Contingency Plan and Corrective Actions).

Monitoring for the HDD segments will be from the following locations:

-   For the HDD segment under the Susquehanna River and Back River,
    Environmental Inspectors will patrol the waterway by boat to
    visually inspect for drilling fluid releases.

-   For the HDD segment under the remaining crossings, Environmental
    Inspectors will be on foot on access ways and developed lands that
    provide a clear view of the crossing area to visually inspect for
    drilling fluid releases.

# contingency PLAN and Corrective Actions

## General

A number of scenarios that could occur during HDD operations have been
identified and appropriate corrective measures have been prepared. A
list of unlikely but possible incidents that could occur during HDD
operations is as follows:

-   Drilling fluid releases, or other loss of drilling fluid into the
    aquatic environment;

-   Failure during reaming;

-   Breakage of the drill bit;

-   Failure of the drill head guidance and positioning system;

-   Failure of the HDD;

-   Failure of pipeline pull-in (pipe-stick during pull-back);

The Chain-of-Command for communicating and implementing corrective
actions in response to releases or other problem conditions is
summarized below.

## Drilling Fluid Releases

If one or more of the above events causes a release of drilling fluid
within any wetland or waterbody, the following measures will be
implemented to stop or minimize the release and to clean it up:

### HDD Land Segments

Should a release of drilling materials occur on land that can be
accessed without impact to wetlands, barriers (i.e. hay bales, sand
bags, silt fences, etc.) will be placed by hand immediately or berms
will be constructed around the site to contain the release. Collected or
contained drilling fluids will be removed by pump or vacuum truck
positioned landward of any waterbody system so as not to disturb any
wildlife habitat. The drill operators will perform the following
contingency measures as necessary to stop discharges of drilling fluids:

-   Decrease the drilling fluid circulation pressures;

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-   Size the drill hole to remove blockages (i.e. cleaning the drill
    hole to remove potential blockages, thereby allowing the fluid to
    flow within the drill hole and not into the geologic formation);

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-   Thicken the drilling fluid properties by adding bentonite pellets;
    and

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-   If necessary, make adjustments to the drilling alignment.

If necessary, the Environmental Inspector will require that the drilling
operations be reduced or suspended so that the extent of the release can
be assessed and corrective actions, if any are required, can be
implemented.

Containment equipment including earth moving equipment, portable pumps,
hay bales, silt fencing, etc. will be readily available and stored at
the drilling sites. If a release impacts a surface water body or wetland
the reporting procedures referenced in Section VI will be followed. If
the amount of an upland release does not allow practical collection, the
affected area will be diluted with fresh water and allowed to dry.

The drill cuttings generated from the drilling operations will be
stockpiled in water-tight containers at upland locations in a manner
that prevents their release into the waters of the State. Excess
drilling fluid and cuttings will be transported to an authorized
disposal site. No discharge of water or drill cutting to the waters of
the State will be allowed from HDD operations.

## Equipment Failure

In general, if there is a failure of part of the equipment such as the
drill bit or drill head guidance system, the HDD operations will be
suspended if continued operation would pose a risk of releasing drilling
fluid at levels that exceed the applicable permit conditions. For a
malfunction involving the drill head, the drill string will be withdrawn
and the drill head repaired or replaced.

If the pipe becomes stuck during pull-back, efforts will be made to
restart the movement by adding additional drilling fluid or by reaming
ahead of the pipe or by using a hydraulic hammer. If the pipe has only
been pulled part of the way into the hole, it may be possible to recover
the pipe from the entry point. If the pipe becomes irretrievably jammed,
the measures described in Section V abandon the original hole and
redrill a new one will be implemented.

# Abandonment

If corrective actions do not prevent or control unacceptable releases of
drilling fluid from occurring into the waterbody, Mid-Atlantic Express
may opt to redrill the hole along a different alignment. The HDD
borehole would not simply be abandoned completely if difficulties were
encountered during drilling or reaming of the borehole, or during pipe
pullback operations. In fact, complete abandonment of an HDD borehole
rarely occurs within the industry. Instead, prior to abandoning a
borehole, the HDD contractor would implement remedial measures to
attempt to resolve the problems without the need for abandonment of the
borehole. However, if problems with the borehole or section of the
borehole could not be resolved, the affected section of the borehole
would be filled with grout, consisting of non-toxic, non-hazardous
materials, to preclude communication between nearby boreholes. The
following procedures will be implemented to abandon the drill hole:

-   The method for sealing the abandoned drill hole is to pump thickened
    drilling fluid into the hole as the drill assembly is extracted, and
    using enviro plug to create a cap.

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-   Closer to the surface at drilling locations (within approximately 10
    feet of the HDD entrance), a soil cap will be installed by filling
    with soil extracted during construction of the pit and berms.

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-   The borehole entry location for HDD Segments will be graded and
    seeded by the contractor to its original grade and condition after
    the drill hole has been abandoned.

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-   The contractor will drill a second pilot hole beginning near the
    initial entry point along a track that parallels the initial
    borehole.

A root cause analysis of the failed HDD will be conducted in order to
minimize the risk of subsequent failure. The root cause analysis will
guide the development of potential alternatives for the drilling plan.

Depending on the cause of a failure, it would be preferable to continue
to use the partially drilled Pilot Hole already underway, and simply
redirect the drilling deeper or laterally around the cause of the
failure, if possible, rather than initiate a secondary Pilot Hole.

If the cause(s) of the failure indicate that a completely new,
"secondary" Pilot Hole is necessary, the separation distance required
will depend entirely upon the cause of the failure. Mid-Atlantic Express
anticipates that only the drill alignment between the original entry
point and exit point will be adjusted deeper or laterally such that no
additional work areas will be required. Prior to the initiation of a
completely new "secondary" Pilot Hole, a modification must be authorized
by the appropriate agencies.

# Notification and Reporting Procedures

## Notifications

Upon visual detection of an inadvertent release of drilling fluids the
Environmental Inspector will contact the drilling engineer. The location
and time of the start of the release will be recorded. The drilling
engineer will note the drilling fluid pressures and return flows for
indication of volume lost during release. Upon identification of a
situation that has the potential to exceed applicable permit conditions
or cause significant harm to the environment, the Environmental
Inspector will inform the Environmental Manager, who will notify the
appropriate regulatory agencies.

Corrective action and mitigation steps will be implemented in accordance
with Section IV above.

## Reporting

The construction monitoring team will produce a series of reports
detailing field observations, construction progress, and environmental
monitoring results. This will include a weekly report summarizing
environmental monitoring results and a summary report at the end of the
HDD operations.

ATTACHMENT A

**"Waterbody Crossing Susquehanna River HDD", for Proposed Susquehanna
HDD Crossing Layout**

ATTACHMENT B

**"Waterbody Crossing Back River HDD", for Proposed Back River HDD
Crossing Layout**