**AES**

**MID-ATLANTIC EXPRESS PIPELINE**

**PIPELINE HYDROTESTING AND PRE-COMMISSIONING PLAN**

**January 2007**

**TABLE OF CONTENTS**

**1. PROJECT
DESCRIPTION\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....2\
**

**2. DESIGN
CONSIDERATIONS\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...2\
**

**3.
PERMITTING\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...4\
**3.1
Intake\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....4\
3.2
Discharge\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....5

**4.
PRE-COMMISSIONING\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...6\
**4.1 General
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....6\
4.2 Water
Treatment\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...6

**5. FLOODING, CLEANING AND GAUGING
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...6\
**5.1 General
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....6\
5.2 Pipeline
Flooding.....................\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...7\
5.3 Discharge\.....
..................\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....7

5.4 Final Cleaning Records\...
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....7

**6. HYDROTESTING
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....8\
**6.1 General
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....8\
6.2 Pre-Hydrotest of HDD
Segments\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....8\
6.3 Final
Hydrotest\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....9\
6.4 Hydrotest
Failure\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....9

**7.
DEWATERING\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....10\
**7.1 General
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...10\
7.2 Dewatering
Runs\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....10\
7.3 Water
Disposal\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....10\
7.4 Dewatering
Records\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....10

**8.
DRYING\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...11\
**

**9. INERTING AND
PURGING\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...11\
**

**10. PLANT AND
EQUIPMENT\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....11\
**10.1 Water Flooding Spread
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....11

**11. ENVIRONMENTAL
ASPECTS\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....12\
**11.1
Intakes\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....12\
11.2
Discharge\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...12

**12.
REFERENCES\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....13\
**

**APPENDICES**

A. Water Volume Calculations

B. Material Safety Data Sheet for Water Tracing Dye

C. Material Safety Data Sheet for Typical Hydrotest Water Additives

D. Hydrotest Discharge Drawings

**1. PROJECT DESCRIPTION**

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.

As described in Section 1.10 of Resource Report 1, *General Project
Description*, The AES Corporation is considering the possibility of
building a combined cycle cogeneration power plant (Power Plant) on the
Terminal Site. The Power Plant would be configured with one F-Class
combustion gas turbine, one steam turbine, and associated auxiliaries.
It would operate only on natural gas and would produce approximately 300
megawatts (MW) of clean electric power within an area of high energy
demand. The Power Plant would be connected to the local utility electric
system via an overhead transmission line.

This document describes the plan for testing and pre-commissioning of
the Mid-Atlantic Express pipeline. For the purposes of this document,
testing and pre-commissioning refers to the final installation
activities carried out prior to the introduction of natural gas into the
pipeline transportation system.

**2. DESIGN CONSIDERATIONS**

After the new 30" pipeline is constructed, the pipeline must be tested
to at least 140% of the maximum allowable operating pressure (MAOP) for
a period of 8 hours per ASME B31.8, Table 841.322(f). ASME B31.8 is
incorporated by reference in DOT 192. The 8 hour requirement is due to
the inability to inspect the pipe for leakage during the test since the
pipe will be buried. The established MAOP necessary to meet flow
capacity requirements is 2,080 psig. Therefore, the minimum required
test pressure is 2,912 psig at the high point of each test section.
There is no limit on the maximum test pressure although it typically
will be from 95% to 100% of SMYS (Specified Minimum Yield Stress).

AES has performed a class study for the pipeline based on an assessment
of the geographical areas along the Mid-Atlantic pipeline route. Based
on this assessment and the requirements of USDOT, 49 CFR Part 192,
*Transportation of Natural and Other Gas by Pipeline: Minimum Federal
Safety Standards* the majority of the 88 mile route meets criteria for a
Class 3 area with portions of the pipeline route designated as Class 4
areas from MP 1.6 to 9.9 and MP 83.6 to 87.5.

The selected pipe specification for the pipeline in a class 3 location
is 30" OD, 0.938" wt, API 5L X70 grade. The design pressure for the pipe
is 2,189 psig for a Class 3 location. This design pressure exceeds the
desired maximum operating pressure of 2,080 psig.

The selected pipe specification for the pipeline in a Class 4 location
is 30" OD, 1.125" wt, API 5L X70 grade. The design pressure for the pipe
is 2,100 psig for a Class 4 location. This design pressure exceeds the
desired maximum operating pressure of 2,080 psig.

The 88 miles of 30" pipeline from Sparrows Point, Maryland to Eagle,
Pennsylvania will be tested in two sections. Test Section #1 will extend
from the west bank Susquehanna River to the Northern Terminus of the
Pipeline in Eagle, Pennsylvania (MP 43.6 to 87.6). Test Section #2 will
extend from the initiation point of the pipeline at the AES Sparrows
Point LNG Terminal to the west bank of the Susquehanna River (MP 0 TO
43.6). The two test sections are shown on the figures in Appendix D. The
pipeline elevations, test pressures and specified minimum yield stress
for each test section are as follows:

Test Section #1 [Proof test]{.underline} [%SMYS]{.underline} [Max.
test]{.underline} [%SMYS]{.underline}

From MP 43.6 to MP 87.6

Low Elevation @ MP 43.9, 120 ft. 3,137 psig 71.7 4,158 psig 95.0%

High Elevation @ MP 63.3 640 ft. 2,912 psig 66.5 3,933 psig 89.8%

Elevation @ MP 87.6 480 ft. 3,020 psig 68.1 4,041 psig 92.3%

Test Section #2

From MP 0.0 to MP 43.6

Low Elevation @ MP 0.0, 0 ft. 3,167 psig 72.3 4,158 psig 95.0%

High Elevation @ MP 30.25 590 ft. 2,912 psig 66.5 3,903 psig 89.2%

Elevation @ MP 43.6 260 ft. 3,055 psig 69.8 4,046 psig 92.4%

AES has evaluated selected critical water bodies for crossing using the
Horizontal Directional Drilling (HDD) method, consistent with the
request by National Marine Fisheries Service (NMFS). As described in
Resource Report 2, *Water Use and Quality*, to avoid potential impacts
to wetlands and water-bodies, and potential disruption of local traffic
(highway and rail), AES has proposed two (2) HDD sections for the
pipeline.

0.  

As shown on the figures included in Appendix D, the locations of these
HDD sections are:

-   HDD #1 - MP 9 crosses Back River, approximately 2 miles east of the
    city of Baltimore, located in Baltimore County, Maryland.

-   HDD #2 -- MP 43.6 crosses the Susquehanna River, between Darlington,
    Harford County and Conowingo, Cecil County, Maryland.

**3. PERMITTING**

Before any segment of proposed Pipeline is placed in-service, it will be
hydrostatically tested to ensure it conforms to U.S. Department of
Transportation (Part 192) specifications. Water will be required during
the pre-commissioning operations of the Mid - Atlantic Express Pipeline
for flooding, cleaning, and hydrotesting. Hydrotesting will be required
for the following sections and segments of the pipelines:

-   Test Segment #1 from MP 43.6 , Darlington, Harford County, Maryland,
    to MP 87.6, Uwchland, Chester County, Pennsylvania.

-   Test Segment #2 from MP 0.0, Sparrows Point, Baltimore County,
    Maryland, to MP 43.6, Darlington, Harford County, Maryland

-   Each of the two HDD sections listed in Section 2. above (HDD#1 and
    HDD#2)

A total of approximately 7,600,000 gallons of water will be required for
flooding, cleaning and hydrotesting of the pipeline.

Potential impact to sensitive waterbodies (fisheries) has been
considered in the preparation of this hydrostatic test plan. AES
currently plans to withdraw the hydrostatic test water from the
Susquehanna River. Prior to withdrawal of hydrostatic test waters, AES
will coordinate surface water withdrawal with the Susquehanna River
Basin Commission (SRBC), and will obtain as well as a Permit to
Appropriate and Use Waters of the State from the Maryland Department of
the Environment (MDE), as further described below in Section 3.1. AES is
also evaluating the feasibility of drawing the hydrostatic test water
from the Baltimore County POTW or another public water supply.

Once the hydrostatic test is completed, AES will need to discharge the
hydrostatic test waters. Prior to initiation of the hydrostatic test,
AES will apply for coverage under the Maryland General Permit for
Discharge of Hydrostatic Test Waters (COMAR 26.08.04.09.K) as further
described below in Section 3.2.

**3.1 Intake**

> Prior to withdrawing water from State of Maryland waters for use
> during pre-commissioning, Mid-Atlantic Express will obtain a Water
> Appropriation and Use Permit from the MDE Water Management
> Administration (WMA) in accordance with COMAR 26.17.06. Additionally,
> AES will coordinate surface water withdrawal with the Susquehanna
> River Basin. Water used for hydrostatic testing of the Susquehanna
> River directional crossing will be taken from the Susquehanna River.
> Hydrostatic test water used for testing the directional crossing at
> the Back River will be potable water hauled to the test site by
> transport trucks. Water used for hydrostatic testing the installed
> pipeline will be taken from the Susquehanna River. Potential impact to
> sensitive waterbodies (fisheries) has been considered in the
> preparation of this hydrostatic test plan. The hydrostatic test water
> intake structures will be designed avoid juvenile and adult fish
> entrainment and the disturbance of bottom sediments by placing
> restrictions on bottom draw and requiring a screen at the intake as
> well as velocity controls consistent with EPA guidance and permits
> from local agencies.
>
> Maryland's cooling water intake and discharge regulations (COMAR
> 26.08.03) stem from Sections 316(a) and (b) of the CWA. COMAR
> 26.08.03.05, and litigative and administrative rulings stipulate that
> the location, design, construction and capability of cooling water
> intake structures must reflect the best technology available (BTA) for
> minimizing adverse environmental impacts, providing that the costs of
> implementing the BTA are not wholly disproportionate to the expected
> environmental benefits. Maryland law exempts facilities with
> withdrawal rates less than 10 million gallons per day (MGD) and less
> than 20 percent of stream or net flow by the intake. Maryland's
> regulations do not specify a design intake velocity, and typical
> Maryland facilities generally have a 1 to 2 fps screen face velocity.
>
> While AES does not propose to construct a cooling water intake system,
> these regulations were utilized as the guidance for the conceptual
> design of the proposed hydrostatic test water intake structure that
> would be used to provide hydrostatic test water for each pipeline
> segment. As such the hydrostatic test water intake structure will be
> designed to minimize entrainment of marine organisms through effective
> use of a low velocity suction intake system, designed for less than 2
> fps with a velocity-cap. Both water intake and discharge are
> anticipated to be from location(s) within the new pipeline ROW
> corridor where it crosses the Susquehanna River, with the intake
> structure extending from the west bank of the river.

**3.2 Discharge**

> AES will obtain coverage under the Maryland General Permit for
> Discharge of Hydrostatic Test Waters (COMAR 26.08.04.09.K), General
> Permit No 06HT. In accordance with the permit conditions AES will file
> a Notice of Intent with MDE WMA at least sixty calendar days prior to
> commencement of activities covered under the general permit. AES will
> notify the MDE at least 48 hours prior to discharge and will perform
> sampling and analysis of the discharge in accordance with the Section
> IV.D of the General Permit, Discharge Limits for Hydrostatic Testing
> of Pipes, Pipelines and Tanks including the following flow rate, oil &
> grease, total iron, total residual chlorine, total suspended solids,
> dissolved oxygen, temperature difference, temperature and pH. The
> sampling and analytical methods used will conform with the procedures
> for the analysis of pollutants as identified in 40 CFR Part 136.
> Dewatering of the pipeline test sections will be conducted as
> described in Section 7 and in accordance with applicable permit
> conditions. The following table shows the locations and volumes to be
> discharged.

+---------------+-----------------+---------+-------+-----------------+
| **Table 3-1** |                 |         |       |                 |
|               |                 |         |       |                 |
| **Hydrotest   |                 |         |       |                 |
| Water         |                 |         |       |                 |
| Discharge     |                 |         |       |                 |
| Locations and |                 |         |       |                 |
| Volumes**     |                 |         |       |                 |
+---------------+-----------------+---------+-------+-----------------+
| **Discharge   | **Purpose of    | *       | **D   | **Receiving     |
| Location**    | Discharge**     | *Volume | ischa | Water Name**    |
|               |                 | in      | rge** |                 |
|               |                 | Gal.**  |       |                 |
|               |                 |         | *     |                 |
|               |                 |         | *MP** |                 |
+---------------+-----------------+---------+-------+-----------------+
| Directional   | Susquehanna HDD | 149,000 | 43.6  | Area of         |
| Drill Site,   | Hydrotest water |         |       | considerable    |
| Susquehanna   |                 |         |       | vegetation;     |
| River         |                 |         |       | Tract 655, West |
|               |                 |         |       | Bank            |
|               |                 |         |       | Susquehanna     |
|               |                 |         |       | River           |
+---------------+-----------------+---------+-------+-----------------+
| Local POTW    | Back River HDD  | 27,175  | Test  |                 |
|               | Hydrotest water |         | water |                 |
|               |                 |         | will  |                 |
|               |                 |         | be    |                 |
|               |                 |         | h     |                 |
|               |                 |         | auled |                 |
|               |                 |         | of    |                 |
|               |                 |         | fsite |                 |
|               |                 |         | by    |                 |
|               |                 |         | tran  |                 |
|               |                 |         | sport |                 |
|               |                 |         | truck |                 |
+---------------+-----------------+---------+-------+-----------------+
| Pipeline Test | Pipeline Test   | 7,      | To    | Test water will |
| Segment #2    | Section #1      | 315,000 | Test  | be pumped into  |
| for re-use    |                 |         | Se    | Test Section    |
|               | MP 43.6 -- MP   |         | ction | #2; No          |
|               | 87.6 Hydrotest  |         | #2    | discharge to    |
|               | water           |         |       | waterbody.      |
+---------------+-----------------+---------+-------+-----------------+
| Upland area   | Pipeline Test   | 7,      | 43.6  | Area of         |
| in the        | Section #2      | 400,000 |       | considerable    |
| vicinity of   |                 |         |       | vegetation;     |
| the           | MP 0 -- MP 43.6 |         |       | Tract 655, West |
| Susquehanna   | Hydrotest water |         |       | Bank            |
| River         |                 |         |       | Susquehanna     |
|               |                 |         |       | River           |
+---------------+-----------------+---------+-------+-----------------+
| Note: Exact   |                 |         |       |                 |
| discharge     |                 |         |       |                 |
| locations may |                 |         |       |                 |
| be optimized  |                 |         |       |                 |
| based on      |                 |         |       |                 |
| field         |                 |         |       |                 |
| conditions    |                 |         |       |                 |
| and           |                 |         |       |                 |
| contractor    |                 |         |       |                 |
| construction  |                 |         |       |                 |
| methods.      |                 |         |       |                 |
+---------------+-----------------+---------+-------+-----------------+

**4. PRE-COMMISSIONING**

**4.1 General**

> The pre-commissioning activities for the Project will be carried out
> as one activity. The main pipeline section will include the entire
> Mid-Atlantic Pipeline from Sparrows Point, Maryland (MP 0.0) to its
> terminus in Eagle, Pennsylvania (MP 87.6).
>
> The pre-commissioning activities for both proposed hydrotest sections
> include the following:

-   Filling, Cleaning and Gauging

-   Hydrotesting

-   Dewatering

-   Drying

-   Purging

-   Inerting

**4.2 Water Treatment**

> In the past, the generally accepted industry practice was to treat all
> water entering a pipeline to prevent corrosion. Due to environmental
> concerns, the current accepted industry practice is to avoid the use
> of chemical additives, except under circumstances where the test water
> will remain in the pipeline for a period exceeding one month. This
> practice is based on the fact that once initial corrosion occurs, the
> corrosion creates a very thin layer of rust, and oxygen-induced
> corrosion will gradually be diminished. The remaining risk to the
> pipeline will be predominantly due to the presence of microbiological
> organisms (e.g. sulfate reducing bacteria (SRB) and acid reducing
> bacteria (ARB)).
>
> The Mid Atlantic Express pipeline will be internally coated, which
> will protect the pipeline from corrosion and the only areas
> potentially susceptible to corrosion (i.e. uncoated sections) are one
> foot either side of the field joints. Due to this limited potential
> for corrosion and the short residence time of the hydrotest water in
> the pipeline (i.e. less than one month) the use of corrosion
> inhibitors will not be necessary.

**5. FLOODING, CLEANING AND GAUGING**

**5.1 General**

> Pipe Test Section 1 and Section 2, respectively, will be partially
> flooded prior to the introduction of scrapers (pigs) in order to avoid
> uncontrolled pig acceleration due to gravity and the force of the
> static head of the water behind the pig. After flooding, cleaning will
> be carried out to ensure that all construction debris, dust, dirt,
> mill scale and rust are removed from the pipeline. Construction debris
> dirt, mill scale, and rust will be collected by the contractor in the
> pig traps at the end of each line segment, loaded in containers and
> hauled offsite to approved disposal facilities. High velocity water
> flushing may be used (3 -- 6 ft/sec) to displace mill scale, loosely
> adhering sand, and debris from the pipeline. A train of pigs
> specifically designed for cleaning will be propelled along the
> pipeline as part of the flooding and cleaning operation. Since the
> pipeline is internally coated, polyurethane scraper pigs, instead of
> brush pigs, will be used.
>
> The pig train will also include a pig fitted with a gauging plate. A
> gauging pig will be sized to 95% of the nominal internal diameter of
> the pipeline. This is a specially machined disc used to verify the
> internal diameter of the pipeline and to ensure that there are no
> buckles, dents, or excessive ovality.

**5.2 Pipeline Flooding**

> Once installed, Test Section 1 will be filled using water pumped from
> the Susquehanna River. No additives will be used.
>
> Listed below are proposed sources of water:
>
> A total of approximately 7,315,000 gallons of water will be required
> for filling and hydrotesting of Test Section #1. Test Section #1
> includes a second hydrotest of the HDD of the Susquehanna River. Water
> will be drawn from the Susquehanna River, the designated source, the
> intake pipe will be installed with screens and filters and the intake
> velocity will be restricted to less than 2 ft/sec. In this way, the
> potential for entrainment or entrapment of aquatic organisms will be
> minimized.
>
> Following a successful hydrotest of Section #1, the 7,315,000 in Test
> Section #1 will be pushed using pigs and compressed air into Test
> Section #2. An additional 85,000 gallons will then be pumped from the
> Susquehanna River as needed to fill Test Section #2. Test Section #2
> includes a second hydrotest of the Back River HDD.

**5.3 Discharge**

> Any water used to flood, clean and hydrotest the pipeline will be
> discharged as outlined in Section 7 below. During the cleaning
> operation, the fill water will be channeled into a holding pool or
> temporary holding tank, filtered, tested and then discharged in
> accordance with applicable permit limits. Water treatment will be
> limited primarily to the removal of debris and contaminants unless
> circumstances dictate otherwise, since no chemicals will be used
> during the operation. See section 4.2 for water treatment.
>
> If it is determined, after water analysis has been completed, that the
> hydrotest water can be discharged in uplands without pretreatment, the
> test water will be released to the ground at a controlled rate
> utilizing preventative measures to avoid erosion that may include
> discharge via a diffuser, discharge into riprap, discharge into a
> splash barrier and/or control of flow rates to avoid erosion of soil
> in accordance with applicable permit conditions. See Figure 25,
> Typical Pipe Test Energy Dissipater in Appendix D of this document.
>
> Any solid residue recovered during cleaning, will be collected and
> disposed off at a disposal site licensed for the particular type of
> waste.

**5.4 Final Cleaning Records**

> In the final cleaning records, the following data will be measured and
> recorded:

-   Total volume, pressure and flowrate of cleaning medium for each
    cleaning step.

-   Quantities and composition of materials recovered at the end of the
    pipeline.

-   Water disposal information.

-   Data recording records required by applicable permits.

**6. HYDROTESTING**

**6.1 General**

> After the pipeline has been cleaned of debris and voided of air,
> hydrotesting of the pipeline can commence. Hydrotesting involves
> pressurizing the pipeline to a predetermined pressure level and, after
> stabilization, maintaining the pressure at that level for a set time
> period.
>
> The Mid Atlantic Express pipeline will be tested in accordance with
> current industry standards, i.e., U.S. Department of Transportation
> (DOT ) "Transportation of Natural and other Gas by Pipeline: Minimum
> Federal Safety Standards," Title 49 CFR Part 192, and ASME B31.8, "Gas
> Transmission and Distribution Piping Systems." The pipeline and the
> use of the HDD segments will require a minimum hold time of 8 hours.
> Individual HDD sections will be tested prior to installation above
> grade for 4 hours and then tested again once the pipeline has been
> assembled. Pipeline integrity will be demonstrated by the absence of
> any pressure loss, other than that which can be attributed to
> temperature fluctuation.

**6.2 Pre-Hydrotest of HDD Segments**

> Each of the HDD pipeline segments will be individually hydrotested to
> confirm the integrity of each segment before it is pulled through the
> reamed bore. After installation and tie-in, the HDD segments will be
> re-tested during hydrotesting of the assembled sections of the
> pipelines.
>
> The HDD segments are short in length relative to the length of the
> overall pipelines. Consequently, close monitoring and control during
> segment construction will ensure internal cleanliness, minimizing
> construction debris. Therefore, there should be little concern
> regarding contamination of the water to be discharged following the
> hydrotest. Nonetheless, this test water will be sampled and tested
> prior to discharge. If the water meets applicable permit requirements
> and can be discharged without pretreatment, the test water will be
> released on to the ground and monitored closely to avoid erosion of
> soil. If treatment is required prior to discharge, the test water will
> be treated, re-tested and then discharged. The neutralization of the
> hydrotest water will be performed by adding a neutralizing agent such
> as hydrogen peroxide. The continuous analysis of the hydrogen peroxide
> dosage rate and its effect on the neutralization process will dictate
> the hold period prior to discharge.
>
> Solid residuals will be collected and disposed of at a licensed
> disposal site.
>
> The proposed discharge locations for all hydrotest operations are
> presented above in Table 3-1 and shown on the attached drawings in,
> Appendix D.

6.2.1 HDD Segments

> Approximately 27,175 gallons of potable water from a municipal source
> will be used to flood and hydrotest the Back River HDD segment. The
> potable water used for the hydrotest will be obtained from a local
> municipal source trucked in to the construction area. The water will
> be filtered prior to filling the pipeline segment.
>
> After testing, the Back River HDD segment will be dewatered following
> the hydrotest, subject to installation and tie-in requirements. Prior
> to discharge, the water will be sampled and tested for contaminants to
> prevent environmental pollution. Hydrostatic test water fro the Back
> River HDD test segment will be discharged to trucks and transported to
> a local POTW where it will be discharged in compliance with the
> applicable permit requirements. Discharge locations are shown in the
> Table 3-1, Hydrotest Water Discharge Locations and Volumes
>
> Approximately 149,000 gallons of water will be used to flood and
> hydrotest the Susquehanna River HDD Segment. The water will be
> obtained from the Susquehanna River in accordance with local permit
> conditions. The water will be filtered prior to filling the pipeline
> segment. After testing the Susquehanna River HDD Segment the pipe
> section will be dewatered, subject to installation and tie-in
> requirements. Prior to discharge, the water will be sampled and tested
> for contaminants to prevent environmental pollution. Discharge
> locations are shown in Table 3-1, Hydrotest Water Discharge Locations
> and Volumes

6.2.2 Pipeline

> Approximately 7,400,000 gallons of fresh water will be used to flood
> and hydrotest the pipeline. The water will be filtered prior to
> filling the pipeline segment. The ends of the pipeline segments will
> have test heads installed on each end. These heads will be fitted with
> valve mechanisms and hoses that will allow the pipeline to be flooded.
> One of the test heads will have a pre-installed pig to expel any air
> trapped in the segment prior to the hydrotest. The same pig can be
> pushed back with compressed air for dewatering, if required.
>
> The test section and the terminal ends of the pipe section will be set
> up with warning signs, bunting and barricades to restrict unauthorized
> access during hydrotesting.

**6.3 Final Hydrotest**

> The water remaining in the pipeline at the end of the cleaning and
> flushing operations, including recovery of all pigs will be used as
> the water for the hydrotest. Pressurization starts after an initial
> stabilization of water temperature and pressure.
>
> The pipe segment will be pressurized according to the following:

-   The initial pressurization of the pipeline will be maintained for
    approximately 24 hours at a lower pressure to allow the system to
    stabilize. After this time has elapsed, the pipeline pressure will
    be increased to the final hydrotest pressure.

-   When a stable hydrotest pressure has been achieved, it will be
    maintained for the duration during which time the pipeline pressure
    and ambient temperature will be continuously monitored and recorded
    using pressure gauges, transmitters, and temperature probes. If it
    is necessary to prevent the pressure inside the pipeline from
    exceeding the maximum allowable pressure, water will be released in
    a controlled manner consistent with permitting requirements. Records
    of the volumes of injected water will be maintained.

-   Minimum total test duration will be 8 hours per Table 841.322(f) in
    ASME B31.8, "Gas Transmission and Distribution Piping Systems".

**6.4 Hydrotest Failure**

> In the event the pipeline system fails to hold the hydrotest pressure,
> all potential leak pathways will be determined and examined
> immediately. A pressure cross-correlation will be performed to
> ascertain the extent and probable location of the leak(s).
> Instrumented tools, e.g., pigs with hydrophones or ROV deployed leak
> detection equipment will initially be used to locate the leak if
> suspected in a HDD segment. As a last resort, if these techniques are
> unsuccessful for the in water portion, then dye will be injected into
> the hydrotest water to help identify the leak location. The crew will
> therefore be available to perform any corrective measures that may be
> required.

**7. DEWATERING**

**7.1 General**

> After completion of the hydrotest, the pipeline will contain test
> water that must be removed. Since the base case for pre-commissioning
> is not to use water inhibition or chemical additives, water discharge
> is simplified. The only potential environmental concern will be
> sediment and suspended debris. These will be removed by filtration and
> the use of sedimentation pools or temporary holding tanks, before
> discharge into the environment. Water sampling and testing will be
> performed to ensure compliance with current environmental regulations
> and permits obtained for the project, which are in force in the
> relevant areas of discharge as described in Section 3.2. Displacement
> of the water from the pipeline section will be performed using
> dewatering pigs driven by dry compressed air.

**7.2 Dewatering Runs**

> The dewatering operation will continue until no further water is
> recovered. Dry compressed air is the medium used to propel the
> dewatering pigs. The average speed of the dewatering train will be in
> the order of 2 - 3 ft/sec.

**7.3 Water Disposal**

> Approximately 7,400,000 gallons of water will be discharged from the
> pipeline following a successful hydrotest of all sections.
> Approximately 149,000 gallons of water will be discharged from the
> Susquehanna HDD Segment Hydrotest and approximately 27,175 gallons of
> water will be discharged following the hydrotesting of the Back River
> HDD Segment.

**7.4 Dewatering Records**

> Details of test water and other media disposed from the receiving end
> will be recorded. These include:

-   Salt content of the last water batch at the receiving end, if
    applicable;

-   For each de-watering run, the quantities, pressure and flow rate
    records of the driving medium;

-   Water disposal information and composition

-   For the final run, the dewpoint records of the air.

-   The data recording requirements per applicable permit conditions.

> If the water from the pipeline, after water analysis has been
> completed, can be discharged without pretreatment, the test water will
> be released in an upland location through an energy dissipater which
> will flow into the Susquehanna River, in compliance with applicable
> permit limits.
>
> Any solid residue recovered during cleaning will be collected and
> disposed off at a licensed disposal site.

**8. DRYING**

Drying of the pipeline will be carried out immediately following
dewatering. Various techniques can be used, including:

-   Chemical swabbing;

-   Air drying; and

-   Vacuum drying.

The use of the vacuum drying process is dependent upon a thorough
dewatering and will be evaluated at a later date. Due to the length of
the pipeline and its undulating profile, drying will be performed from
both ends to reduce the drying time if the vacuum drying process is
used. In order to reduce the drying time, however, it will be beneficial
to use a combination of chemical swabbing, followed by air drying. The
chemical swabbing using monoethylene glycol (non-volatile with a low
vapor pressure) can be used in three slugs, separated by pigs. The
entire train can be propelled by super-dry air. Upon recovery of the
swabbing train, the glycol slugs will be sampled for water content. The
used glycol will be recovered and recycled for further use on other
projects, If AES chooses to dispose of the used glycol versus recycling
it for reuse, then it will obtain applicable permits and dispose of it
at an approved disposal facility. Dry air purging will then continue
until the specified dew point for the pipeline is attained.

**9. INERTING AND PURGING**

Following the drying operation, purging of the pipeline with nitrogen
will be required prior to the introduction of natural gas. This is
necessary to reduce the oxygen concentration and prevent mixtures of gas
and oxygen that are combustible. Upon completion of the purging
operation, the pipeline typically will be full of low-pressure nitrogen
(between 10 and 30 psig).

Purging will continue until the dew point at the discharge end remains
below the specified dew point while replacing twice the content of the
pipeline at purging pressure.

**10. PLANT AND EQUIPMENT**

**10.1 Water Flooding Spread**

> The pumping equipment will be located at one end of the pipeline. The
> water will be filtered through 50 micron filters and will be left in
> the pipeline for no more than 30 days.
>
> Prior to flooding, hydrotest heads will be fitted to both ends of the
> segment/section to be tested. These heads will allow the insertion and
> removal of pigs. A pig-launching station, which includes a filter and
> pump unit, will be installed at one end of the pipe segment. A
> temporary pig receiver, drain line and vents will be installed on the
> other end. A portable compression station with containerized units and
> portable offices will be located at the receiving end.
>
> All activities and equipment for the initial hydrotesting of the HDD
> segments will be confined within the temporary work areas designed for
> each HDD crossing.
>
> 10.1.1 Pipeline Hydrotests
>
> The hydrotest of the entire pipeline segment will be conducted in two
> Test Sections. Testing equipment will be located on the west bank of
> the Susquehanna River. Pressure gauges will also be located at the
> facility end to monitor the hydrotest pressures.
>
> 10.1.2 Dewatering and Drying
>
> Air compressors will be placed at Sparrows Point to dewater towards
> the interconnection points. Drying will also be performed towards the
> interconnection points. The pipeline will then be purged with nitrogen
> from the Sparrows Point site in preparation for gas transmission.

**11. ENVIRONMENTAL ASPECTS**

The internal surface of the pipeline will be coated with a protective
film coating, which is generally non-toxic. However, Mid Atlantic
Express will perform toxicity testing for the selected internal coating
prior to coating the pipe. The results of the toxicity testing will be
provided to DEP and DPEP for review.

**11.1 Intakes**

> The intake pipe will be installed with screens and filters and the
> intake velocity will be restricted to less than 2 ft/sec. This
> approach minimizes the potential for entrainment or entrapment of
> aquatic organisms.
>
> Prior to discharge of any water to State Waters, the water will be
> tested to ascertain if it is within the limits of the permit and
> within the limits for chemical concentrations specified in Maryland
> General Permit for Discharge of Hydrostatic Test Waters (COMAR
> 26.08.04.09.K), General Permit No 06HT. The discharge of water from
> the hydrotest of the offshore HDD segments will be conducted no less
> than 400 feet from any sensitive species. The filtered water when
> discharged is not expected to have a detrimental impact on marine
> biota.
>
> The intake velocity and aperture size of the intake screens will be
> designed to minimize the rates of impingement and entrainment, based
> on consultations with NMFS the screen size will be less than 2 mm. It
> is possible that organisms smaller than the aperture size of the
> screens and that swim at a slower rate than the intake velocity could
> be drawn in with the test water, while larger, slow moving biota could
> be trapped on the screens for the length of time it takes to fill the
> pipeline segment.
>
> To address potential impact to marine organisms and biota, the intake
> velocity of the system will be restricted to less than 2 ft/sec, with
> a flow rate of approximately 1,200 -- 3,600 gallon/min so that the
> potential for entrainment of marine biota is minimized. The screen
> through which the water is drawn will be sized to minimize the rate of
> impingement on the screens while the pipeline is filling.
>
> As a result, minimal impact to marine biota will occur at the water
> intake locations.

**11.2 Discharge**

> It is not anticipated that additional chemicals will be required. Mid
> Atlantic Express will sample and test the water prior to discharge. If
> required, the water will be treated to the level required such that it
> complies with any and all licenses and permits required for discharge
> and does not detrimentally affect the quality of the receiving waters.
>
> There is not expected to be a thermal impact to the discharge water
> body due to the discharge of water used in the hydrotest procedures.
> With regard to the hydrotests of the HDD segments, the water will only
> be retained in the segments for a short time and the volumes contained
> within the segments will be small enough that the thermal plume will
> be limited and will dissipate quickly.
>
> The setback distances for hydrotest and leak test discharges were
> conservatively selected and are protective of nearby sensitive
> receptors due to the use of seawater in the test operations, absence
> of chemical additives and the use of intake controls and diffusers to
> control velocity during intake and discharge.
>
> Each discharge location is shown in Table 1 and on the drawings
> included in Appendix D.

**12. REFERENCES**

The following documents were utilized in the preparation of this
document:

1.  ASME B31.8, "Gas Transmission and Distribution Piping Systems".

2.  DOT 49 CFR Part 192, "Transport of Natural and Other Gas By Pipeline
    Minimum Federal Safety Standards".

**APPENDIX A\
WATER VOLUME CALCULATION\
**

> **TYPICAL WATER VOLUME CALCULATION FORMULA**

**V = L x ( 3.1416 x D^2^ / 4 ) x 12 / 231**

**Where: V = Gallons required to fill test section**

**L = Length of test section, feet**

**D = Inside diameter of pipe, inches**

> This calculation is to estimate the volumes of water required for test
> sections to flood/ clean/ gauge operation and hydrotest operation.
>
> **APPENDIX B**
>
> **MATERIAL SAFETY DATA SHEET\
> FOR TYPICAL HYDROTEST WATER ADDITIVES\
> AND SWABBING**

**BRIGHT DYES -- WATER TRACING DYE FLT YELLOW/GREEN PRODUCTS**

> **APPENDIX C**
>
> **MATERIAL SAFETY DATA SHEET\
> FOR TYPICAL HYDROTEST WATER ADDITIVES\
> AND SWABBING\
> **

**EQUISTAR CHEMICALS -- MONOETHYLENE GLYCOL, CHEMICAL FOR SWABBING AND
DRYING THE PIPELINE. MSDS #3265**

**APPENDIX D\
HYDROTEST DISCHARGE LOCATION DRAWINGS\
**

HDD -- Mid-Atlantic Pipeline Crossing of Susquehanna River

Test Section #1 -- Mid-Atlantic Pipeline

Test Section #2 -- Mid-Atlantic Pipeline

TYPICAL HYDROTEST DISCHARGE ENERGY DISSIPATOR

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