APPENDIX I 

DRAFT HORIZONTAL DIRECTIONAL DRILLING CONTINGENCY PLAN 
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TABLE OF CONTENTS 

1. Introduction .............................................................................................................. 1

2. HDD Technique........................................................................................................ 4

2.1. Pilot Hole Installation Process........................................................................... 4

2.2. Reaming and Swabbing Processes .................................................................. 5

2.3. Pullback Process .............................................................................................. 5

3. Potential Modes of HDD Failure............................................................................... 6

3.1. Failure Modes during Pilot Hole Installation Process ........................................ 6

3.2. Failure Modes during Reaming and Swabbing Processes................................ 6

3.3. Failure Modes during Pullback Process............................................................ 7

4. HDD Failure Mitigation ............................................................................................. 7

4.1. Mitigation during Pilot Hole Installation Process ............................................... 7

4.2. Mitigation during Reaming and Swabbing Processes ....................................... 8

4.3. Mitigation during Pullback Process ................................................................... 8

5. Frac-Out Failure and Mitigation................................................................................ 9

5.1. Frac-out Definition............................................................................................. 9

5.2. Drilling Fluid Characteristics.............................................................................. 9

5.3. Potential Environmental Impacts from Frac-outs ............................................ 11

5.3.1. Frac-outs to Water................................................................................... 11

5.3.2. Frac-outs to Marsh................................................................................... 11

5.3.3. Frac-outs to Uplands ............................................................................... 12

5.4. Frac-out Prevention ........................................................................................ 12

5.4.1. Design...................................................................................................... 12

5.4.2. Construction............................................................................................. 13

5.5. Monitoring for Frac-outs.................................................................................. 13

5.5.1. Pump Pressure ........................................................................................ 14

5.5.2. Circulation Rate ....................................................................................... 14

5.5.3. Ground Surface Inspection ...................................................................... 14

I-i Appendix I 
5.5.4. Surface Water Inspection......................................................................... 15

5.5.5. Special Safety Considerations ................................................................. 15

5.5.6. Notifications ............................................................................................. 15

5.6. Initial Response to a Frac-out ......................................................................... 15

5.7. Containment and Removal.............................................................................. 18

5.7.1. To Surface Waters................................................................................... 18

5.7.2. In Marsh................................................................................................... 19

5.7.3. On Uplands.............................................................................................. 22

5.8. Impacts Assessment....................................................................................... 23

6. Definition of HDD Failure and Abandonment Criteria............................................. 23

6.1. Criteria for Pilot Hole Failure........................................................................... 23

6.2. Criteria for Reaming and Swabbing Failure .................................................... 24

6.3. Criteria for Pullback Failure............................................................................. 25

7. KMLP/Agency Communication .............................................................................. 26

I-ii Appendix I 
1. Introduction 

The scope of the proposed Kinder Morgan (KM) Louisiana Pipeline project includes the 

installation of 132.2 miles of 42-inch diameter pipeline referred to as Leg 1, 1.2 miles of 

36-inch diameter pipeline referred to as Leg 2, and 2.3 miles of 24-inch referred to as 

the FGT Lateral. Evaluation of the proposed pipeline right-of-way (ROW) has identified 

potential impacts to several features that could be mitigated by crossing using horizontal 

directional drilling (HDD) instead of conventional pipe installation methods, such as the 

open cut method. These features include wetlands, water bodies, canals, and some 

roads. HDD crossings have been identified only in Leg 1 of the Project. As described 

in Resource Report 1, HDD method provides minimal planned disturbance of the 

surface between the entry and exit points of the HDD. Within Resource Reports 1 and 

2, Tables 1-10, 1-12 and 2-2 identify proposed HDD crossings by milepost. Some of 

these milepost sections contain multiple consecutive (i.e., back-to-back) HDD crossings. 

Table 1 presented in this contingency plan summarizes the HDD crossings for the KM 

Louisiana Pipeline project. 

Table 1 Summary of HDD Crossings by Milepost 

Milepost 

Begin End 

Alternative HDD 

Location Relative 

to Original 

Borehole 

Alternative Construction Method(s) 

(In Order of Attempted Application) 

3.93 4.83 50-foot offset 1. Conventional (open cut) water/land lay 

1. Reroute to shorten and re-drill 

17.96 18.62 50-foot offset 2. Conventional (open cut) water lay around 

Shell Island 

18.62 19.41 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional water lay to next HDD 

1. Relocate entry hole to shorten and re-drill, 

conventional water lay from previous HDD 19.41 20.01 50-foot offset 

2. Open cut 

21.17 22.11 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional water/land lay to next HDD 

I-1 Appendix I 
Table 1 Summary of HDD Crossings by Milepost 

Milepost 

Begin End 

Alternative HDD 

Location Relative 

to Original 

Borehole 

Alternative Construction Method(s) 

(In Order of Attempted Application) 

1. Relocate exit hole to shorten and re-drill, 

conventional land lay to previous HDD 22.11 22.71 50-foot offset 

2. Conventional (open cut) water/land lay 

22.71 23.45 50-foot offset 1. Relocate exit hole to shorten and re-drill, 

conventional land lay to next HDD 

23.45 23.95 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional land lay to previous HDD 

25.26 26.03 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional land lay to next HDD 

26.03 26.80 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional land lay to previous HDD 

30.36 31.46 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

marsh-buggy construction to next HDD 

1. Relocate entry hole to shorten and re-drill, 

marsh-buggy construction to previous HDD 

31.46 32.42 50-foot offset 

2. Marsh-buggy construction and conventional 

open cut (wet) waterbody crossing 

43.69 44.48 50-foot offset 1. Conventional land lay and open cut (wet) 

waterbody crossing 

49.57 50.45 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional land lay to next HDD 

50.45 51.30 50-foot offset 1. Relocate exit hole to shorten and re-drill, 

conventional land lay to previous HDD 

51.78 52.37 50-foot offset 1. Conventional (open cut) land lay 

I-2 Appendix I 
Table 1 Summary of HDD Crossings by Milepost 

Milepost 

Begin End 

Alternative HDD 

Location Relative 

to Original 

Borehole 

Alternative Construction Method(s) 

(In Order of Attempted Application) 

1. Relocate exit hole to shorten and re-drill, 

conventional land lay and horizontal bore 

road remainder 52.37 53.05 50-foot offset 

2. Conventional land lay and open cut (wet) 

waterbody crossing 

1. Relocate exit hole to shorten and re-drill, 

conventional upland construction remainder 

77.65 78.40 50-foot offset 

2. Horizontal bore highway, conventional 

upland construction remainder 

99.02 99.76 50-foot offset 

1. Relocate entry or exit hole to shorten and redrill, conventional upland construction 

remainder 

HDD has been used to successfully install pipelines in soils similar to those underlying 

the KM Louisiana Pipeline ROW and in similar conditions. Pipelines up to 42 inches in 

diameter are commonly installed by HDD today. Experienced HDD contractors will be 

utilized for the installation of the HDDs on the KM Louisiana Pipeline Project. The 

combination of experience and historical HDD success in the southern Louisiana area 

strongly suggests that the HDD method will be successful for this Project. In addition, 

HDD feasibility will be further evaluated using geotechnical data collected from soil 

borings to be collected at the individual crossings. This soils data will also be used to 

design the HDD parameters (e.g., entry and exit angles, depth of drill, depth of cover, 

mud mixture specifications, pullback load requirements) specific for each crossing. 

Although not anticipated for this Project, there is always a potential for failure of any 

HDD pipeline crossing. This contingency plan identifies typical modes of failure 

associated with HDD installations, including frac-out or loss of drilling fluid (Section 5). 

Mitigation and/or remedial procedures are identified for these typical issues. 

In the event that the mitigation and/or remedial procedures do not result in a successful 

HDD crossing, this contingency plan presents a decision process to evaluate the 

I-3 Appendix I 
continuation of the HDD method or the adoption of alternative pipeline design or 

installation methods. Generally, if the HDD fails at the original HDD location, KMLP will 

attempt to move to a second, immediately adjacent (50-foot offset), HDD location. 

However, the KM Louisiana Pipeline project ROW is, at some locations, narrowly 

situated between subsurface obstructions, such as other pipelines, or surface 

obstructions, such as rivers and canals. Consequently, a second HDD location may not 

always be available. The anticipated presence or absence of a second HDD location 

offset by 50 feet is identified in Table 1. In the event that HDD method fails at the first 

and, if available, the second HDD location, an alternative design and/or construction 

method is suggested in Table 1. A typical alternative design for a long HDD would be to 

shorten the HDD length, reducing the stress on the equipment and borehole, and 

completing the distance with a more conventional construction method. When 

identifying the alternative method, KMLP considered engineering restrictions, ROW 

restrictions, and potential environmental impacts. 

Pre-construction approval of these procedures should expedite the response time for 

alternative decisions, ensure that appropriate actions are taken that have been preapproved by the agencies, and minimize adverse environmental impacts that may arise 

as a result of frac-outs. HDD installations are typically a 24-hour per day, 7 days per 

week operation, and the objective is to complete each drill in a timely manner with the 

least adverse impacts to the environment. 

2. HDD Technique 

There are three major processes associated with the HDD installation of a pipeline 

crossing: installation of a pilot hole; incremental reaming of the pilot hole followed by 

swabbing the borehole; and pipe pullback. This section discusses each of these steps. 

2.1. Pilot Hole Installation Process 

The pilot hole is drilled along a predetermined alignment in which the entry and exit 

points are located using traditional survey methods. The drill path is monitored by an 

electronics package housed in the non-rotating pilot drill string near the cutting head. 

Where possible, a TruTracker® survey system is used to survey the location of the drill 

path. A wire coil on the surface creates a magnetic field that is detected by the 

electronic housing. Data from the electronic housing is evaluated by the HDD Operator 

and adjustments are made to the drill pathway. 

Initially, the pilot hole, generally a 9-7/8-inch diameter bore, is installed beneath the 

proposed crossing using a jetting assembly in non-consolidated sediments, such as 

I-4 Appendix I 
those anticipated along the proposed KM Louisiana Pipeline ROW, or a downhole 

displacement mud motor connected to a tri-cone rotary bit in consolidated sediments. 

Drilling fluid, pumped through the annulus of the drill stem, performs multiple functions. 

It aids the mud motor or jetting assembly in cutting the soil, lubricates the drill stem, 

suspends and carries the drilled cuttings to the surface and forms a wall cake on the 

interior of the borehole to maintain the integrity of the borehole. 

Installation of the pilot hole is closely monitored to provide data necessary to complete 

the crossing. These data, including the expected penetration rate and geotechnical 

strata confirmation, are used by the HDD Operator to plan the reaming process 

2.2. Reaming and Swabbing Processes 

Beginning at the exit point of the crossing, a reamer is attached to the drill stem and 

passed through the pilot hole to the entry point. For each section of drill stem removed 

from the entry point of the crossing, a section of drill stem is attached to the reamer and 

successive sections of drill stem at the exit point. This newly attached drill stem is used 

to guide the equipment during the return pass of the reamer from the entry side back to 

the exit side of the crossing. Several passes of a 24-inch reamer are used to initially 

enlarge the pilot hole from 9-7/8 inches to 24 inches. Once completed, incrementally 

larger reamers are passed through the borehole until the pilot hole has been enlarged to 

the final diameter appropriate for insertion of the pipe. 

The HDD borehole is then swabbed to clean out remaining soil cuttings and prepare the 

borehole for the pipe. A swab is constructed by welding caps onto a section of pipe the 

same diameter as that to be installed in the borehole. The swab is connected to the drill 

stem and the drilling rig pulls the swab through the borehole. Again, for each section of 

drill stem removed at the entry side of the crossing, a section of drill stem is attached to 

the swab and successive sections of drill stem at the exit side. Depending on the 

borehole, more than one swab may be required to clean the borehole. At completion, 

the swab will be removed from the exit side of the crossing so that the drill stem can be 

attached to the prefabricated 42-inch pipe laid out at the exit side of the borehole. 

2.3. Pullback Process 

After the reaming and swabbing processes have enlarged the borehole to a diameter 

sufficiently large enough to allow the insertion of the prefabricated pipe, a reinforced 

pullhead is attached to the leading end of the pre-fabricated pipe segment in 

preparation for the pullback process. The pullhead is connected by way of a swivel 

head to the drill stem at the exit side of the crossing. Using the drilling rig, the pipe is 

I-5 Appendix I 
pulled through the borehole to the entry side of the crossing. Since the air-filled pipe will 

float in the drilling fluids, a calculated volume of water is added to the pipe sufficient to 

maintain a neutral buoyancy while pulling the pipe. 

3. Potential Modes of HDD Failure 

The potential for failure exists during each process described in Section 2. These 

modes of failure are detailed in the following discussions. In addition, loss of drilling 

fluids or frac-out can occur, typically during the pilot hole installation process. Failure 

due to frac-outs and procedures to handle frac-outs are described in Section 5. 

3.1. Failure Modes during Pilot Hole Installation Process 

The equipment associated with the pilot hole installation process is subject to a large 

amount of stress. If the equipment has not been maintained appropriately, the 

equipment could break. While HDD surface equipment is easily accessed for repair, the 

equipment is very specialized. Equipment that fails down hole must be retrieved in 

order to be repaired or to continue installation of the pilot hole. 

During the pilot hole installation, the borehole can collapse on the drill stem pipe if 

sufficient bentonite cake is not maintained on the walls of the hole, or if stratum 

containing highly fractured rock, glacial till, noncohesive material, or cobbles is 

encountered. If the pilot hole collapses, the torque required to rotate or advance the 

drill pipe increases due to additional friction from the collapsed material. This increased 

friction can freeze the drill pipe in the borehole. Usage of additional torque and tension 

in an attempt to free the equipment can shear or twist the drill pipe into pieces. Multiple 

changes in strata or excessively long drill lengths contribute to the probability of this 

type of failure. 

During pilot hole installation, the horizontal position of the hole is located using 

TruTracker®. When the HDD is below a water body or wetland area that does not allow 

positioning of the surface cable necessary to operate the TruTracker® system, the pilot 

hole may deviate from the designed path. The potential for this failure mode increases 

during long drill lengths. In addition, metal objects located near the pilot hole pathway 

can interfere with the magnetic field generated by the surface cables resulting in 

inaccurate TruTracker® locations. 

3.2. Failure Modes during Reaming and Swabbing Processes 

Caving of the borehole can be a result of insufficient bentonite cake on the walls. This 

failure type is exacerbated during the reaming process. During each pass, a large 

I-6 Appendix I 
volume of drilling fluid is jetted through the reamer. In nonconsolidated soils, the jetting 

energy can carve out caverns causing the hole to become unstable and cave. The 

caved material may prevent recirculation of the drilling fluids causing a build up of 

cuttings in the base of the hole. 

In addition to the problem of the caved material obstructing the borehole, both soil 

collapsed from the borehole and cuttings built up due to poor recirculation of drilling 

fluids increase the friction on the drill pipe. The increased friction could increase the 

potential for pipe failure by shearing or twisting into pieces and consequently for the 

equipment to become lost in the hole. 

3.3. Failure Modes during Pullback Process 

Failure during the pullback process is identified by pipe refusal in either direction. This 

may be due to an insufficiently reamed or swabbed borehole, caving due to lack of good 

bentonite cake on the walls, increased friction on the pipe wall due to positive or 

negative buoyancy, increased friction on the wall of the pipe due to an excessively long 

run, or deterioration of the borehole due to a time lag while the pipe lays idle. 

4. HDD Failure Mitigation 

Generally, the modes of failure identified in Section 3 can be avoided or mitigated prior 

to complete failure of the HDD technique. 

4.1. Mitigation during Pilot Hole Installation Process 

KMLP will implement procedures to avoid failure well before commencement of 

construction. Soil samples collected from borings located near the crossings will be 

evaluated to verify the subsurface geology and to identify a soil layer depth and type 

that will minimize the potential for caving during pilot hole installation. A drilling 

contractor will be identified with experience in HDD installations in similar geology and 

of similar design to the Project. Proper selection of equipment and well maintained 

equipment will minimize the potential for equipment failure during the drilling process. 

The drilling fluid characteristics will be monitored to minimize the potential for caving 

due to insufficient mud cake on the borehole wall. Cuttings will be monitored to ensure 

that circulation has not failed. If the HDD Operator identifies increased stress on the 

drilling equipment due to poor cuttings return or partial collapse of the pilot hole, he can 

adjust the drilling fluid consistency or decrease the drilling rate to allow the drilling fluid 

more time to penetrate the borehole wall and to transport the cuttings from the annulus 

to the surface. In the event that a decrease in drilling fluid or cutting return is noted, the 

I-7 Appendix I 
HDD Operator can also partially pull out of the boring to ream out the pilot hole and 

flush the collected cuttings before they completely plug the borehole. These preventive 

methods minimize stress on the drilling equipment and decrease the potential for 

equipment failure. 

If the pilot hole deviates from the designed pathway, the HDD Operator can correct the 

pilot hole prior to returning to the surface or if the deviation is significant, he can pull 

back, grouting the abandoned section of the pilot hole with bentonite, correct the 

pathway and re-drill that section of the pilot hole so that the pilot hole exits at the correct 

location. 

4.2. Mitigation during Reaming and Swabbing Processes 

During the pilot hole installation, the HDD Operator will monitor soil cuttings, rate of 

advancement, and torque on the drill bit to help identify the characteristics of the 

underlying strata. Referring to this information, he can adjust pump pressure as he 

reams the pilot hole to minimize the potential for caving due to high jetting pressure 

while also adjusting the rate of advancement to maximize the opportunity for the 

cuttings to exit the borehole. However, if caving does occur, the HDD Operator will 

remove the reamer and re-attach the drill bit to re-drill the pilot hole. The reaming 

process can be re-started adjusting for the location of the cave-in as needed. 

4.3. Mitigation during Pullback Process 

Equipment selection is again very important in the pullback process. The drilling rig 

must have sufficient power to not only pull the weight of the longest section of pipeline 

through the borehole but to overcome potential resistance associated with minor caveins during the pullback process. KMLP will ensure that the pipe is prefabricated, tested, 

and ready to be pulled at the completion of the swabbing process. This will decrease 

the potential for lag time and decrease the likelihood of caving associated with extended 

lag time. 

Knowing the density of the drilling fluids and the weight of the pipe, the volume of water 

needed to maintain neutral buoyancy will be calculated and gradually added to the pipe 

as it enters the borehole. The HDD Operator will monitor the drilling equipment for an 

increase in tension that signifies increased friction on the pipe and possible imminent 

refusal. At that time, pulling is halted and the buoyancy is adjusted or, if necessary, the 

pipeline can be removed and the borehole reamed and swabbed. 

If the pipeline does become stuck during the pullback process, the HDD Operator can 

attach an air hammer to the end of the pipeline segment and either hammer the pipeline 

I-8 Appendix I 
I-9 Appendix I 

past the obstruction and through the borehole or hammer the pipeline back towards the 

exit side, freeing the pipe from the obstruction allowing the drilling rig to again move the 

pipeline. 

5. Frac-Out Failure and Mitigation 

This section establishes the procedures for preventing, monitoring, and responding to 

frac-outs of drilling fluids that may occur during the HDDs. The intent of this section is 

to set forth a plan of the actions to be taken, under various conditions and for various 

sizes of frac-outs, should frac-outs occur. There are duplications between the mitigation 

methods described in Section 4 and in this section; however, since frac-out occurrences 

are relatively common during HDD, the duplications were permitted in order to make 

this section as complete as possible. 

5.1. Frac-out Definition 

For the purposes of this procedure, a “frac-out” shall be defined as the unintentional or 

inadvertent loss of drilling fluids from the HDD borehole to the ground surface, other 

than at the borehole entry or exit points. Loss of drilling fluids to the subsurface 

geological formation may result in an apparent reduction in the return of fluids and 

cuttings, but will not be considered a frac-out under this plan unless drilling fluids are 

observed in surface waters or at the ground surface. 

5.2. Drilling Fluid Characteristics 

“Drilling fluids” (often referred to as “drilling mud”) to be used on this Project will be a 

mixture of liquids (mostly fresh water) and solids used in a circulating system in the 

drilling process for the removal of soil cuttings from the borehole, while filling the void 

left by the cuttings, lubricating and cooling the drill string, and sealing the borehole wall 

to eliminate fluid loss and maintain borehole stability. 

Relatively small proportions of approved “additives,” identified in Table 2, may be mixed 

with the drilling fluids. These additives will modify the physical and chemical properties 

of the drilling fluids in order to improve drilling performance or in response to a frac-out. 

The additives will be used when deemed necessary and appropriate by the On-Site 

Mud Engineer, approved by the HDD Superintendent, and in the concentrations 

recommended by the manufacturers and the On-Site Mud Engineer. Other additives 

may be added to the list by the Mud Engineer, if approved by KMLP. 
I-10 

Table 2 Approved Drilling Fluid Additives 

Additive Manufacturer Description Purpose or Use 

Pargel 220® Parchem Mining & 

Waterwell, a division of Smith/Schlumberger Company 

A naturally occurring Wyoming bentonite clay with low sand content 

Lubrication, stabilization of the borehole walls, and the suspension and removal of soil cuttings from the borehole 

Polypac R® A business unit of M-I 

L.L.C. 

100 percent carboxymethylcellulose sodium salt, a polyanionic cellulose polymer 

To control fluid loss and increase the viscosity of the drilling fluid 

Soda Ash A business unit of M-I 

L.L.C. 

100 percent sodium carbonate To increase the pH of the 

drilling fluids to precipitate calcium 

Ringfree® A business unit of M-I 

L.L.C. 

60 to 100 percent acrylic polymer To eliminate or cut mud 

bridging and free up borehole circulation; helps free stuck pipbecause it dissolves sticky clays. 

FSF Polyswell® 

A business unit of M-I L.L.C. 

100 percent acrylamide polymer or copolymer 

Primarily as a lost circulation material. 

My-Lo-Jel® A business unit of M-I 

L.L.C. 

100 percent pre-gelantized starch Fluid loss agent and viscosifier
Refer to the Material Safety Data Sheets (MSDS) in Appendix A for more details on the 

physical, chemical, and environmental characteristics of these non-toxic additives. 

KMLP must approve the use of any additional additives that the HDD Contractor may 

deem necessary to resolve specific drilling difficulties, prior to their use. 

5.3. Potential Environmental Impacts from Frac-outs 

5.3.1. Frac-outs to Water 

Drilling fluids released from an HDD frac-out directly into a surface water body at the 

mud line will be dissipated by the natural currents or blended with the existing solids, 

primarily clay, suspended in the water column. The solids in the drilling fluids are also 

primarily clay, but at low concentrations (no more than 5 percent by volume). 

Inadvertent discharges of the nontoxic drilling fluids may result in a very localized and 

transient increase in suspended solids concentrations, but these increases pose no 

significant threat to public health and safety or to aquatic resources. If an underwater 

frac-out is located in the existing turbid conditions, containment and recovery of the 

drilling fluids would be impractical due to mixing with the surface water. Frac-outs under 

water are a greater impediment to the successful completion of an HDD, due to lost 

circulation, than they are a significant impact on the environment. In the event of a fracout, the HDD Contractor will employ measures described herein to regain proper 

circulation in order to complete the borehole, which in turn should reduce or eliminate 

the frac-out to surface water. As directed by KMLP in consultation with the regulatory 

agency representative, containment may be attempted if sensitive resources, such as 

oyster beds or marsh, are threatened and conditions permit. 

5.3.2. Frac-outs to Marsh 

Several of the HDDs will cross under salt and brackish marsh; in fact, many of the 

HDDs are being performed in order to eliminate direct impacts to marsh from 

conventional pipe installation by trenching. Because of the low concentration (less than 

5 percent) of solids in the drilling fluids, and the natural tendency of the fluid to seek a 

uniform elevation equal to the water level in the marsh, a measurable or permanent 

increase in any ground surface elevation is not likely. If the drilling fluid has a 

particularly high viscosity and the tide is low, a temporary rise might be visible, but this 

will quickly dissipate. On the other hand, the settlement of fines, if of sufficient volume, 

in the marsh may suffocate existing vegetation or affect surface hydrology. Efforts by 

the HDD Contractor to contain and recover frac-out fluids in marsh will also cause 

disturbance of the marsh surface and vegetation by equipment and personnel, and 

I-11 Appendix I 
depending upon its location, such disturbance could offset the benefit gained in 

removing the released fluids. Because it is difficult to predict the net effect of a frac-out 

and attempts to recover the fluids, any frac-outs to the marsh must be evaluated on a 

case-by-case basis and an appropriate level of response mounted as described herein. 

5.3.3. Frac-outs to Uplands 

Uplands crossed by HDD on this project are limited to some road and railroad crossings 

including the I-10 HDD crossing. Environmental impacts will be limited to possible 

surface runoff of fines into adjacent surface waters. Typically the upland crossings are 

readily accessible by conventional construction equipment, so the HDD Contractor will 

perform containment and recovery of drilling fluids utilizing Containment and Recovery 

Equipment listed in Appendix B. 

5.4. Frac-out Prevention 

The first and most effective step in limiting the potential environmental impacts of HDD 

frac-outs is to prevent frac-outs from occurring in the first place. This can be 

accomplished in the conservative design of the HDD profile, as well as by observing 

preventative procedures during the actual HDD crossing. 

5.4.1. Design 

Precautionary measures incorporated into the design of the proposed HDDs to minimize 

the possibility of frac-outs, include: 

a) Geotechnical Investigations 

The soils strata targeted for the majority of the length of each borehole will be selected 

based on physical properties most conducive to producing a successful boring. These 

strata and their properties will be identified in pre-construction geotechnical 

investigations conducted along the length of each proposed HDD installation. 

b) Depth of Cover 

The proposed depth of cover will be maintained at a minimum of 20 feet (and in most 

cases, significantly more) below waterbodies and marsh, except in the initial and final 

100 feet (+/-) where the borings enter and exit the ground. Since the possibility of a 

frac-out may increase as depth of cover decreases, the initial and terminal 100-foot 

sections of each HDD will be located in either upland areas or in open water, and have 

been purposely kept out of marsh areas, where possible. 

I-12 Appendix I 
5.4.2. Construction 

The HDD Contractor will employ reasonable measures during drilling activities to 

prevent or minimize the occurrence of frac-outs, including as a minimum: 

a) On-site Mud Engineer 

A full-time, qualified, mud engineer will be on site. The On-site Mud Engineer will 

continuously monitor the drilling fluid circulation and returns, and ensure that the fluids 

handling equipment is operating within expected and optimum parameters (i.e. 

pressures, flow rates, etc.) for the soils conditions observed. 

The On-site Mud Engineer will continuously monitor returned cuttings for soils type, and 

will modify the drilling fluid properties (i.e. viscosity, density, etc.) with the appropriate 

additives, as he deems necessary to account for changes in soil conditions. 

b) Controlled Drill Head Advance 

Where possible at the beginning of a drill, the drill head will be initially advanced with 

minimum drilling fluid pressure to minimize frac-outs in the relatively shallow depths. 

The HDD Operator will advance the drill head at a pace that permits soils cuttings 

sufficient time to be flushed from the borehole by the drilling fluids. This prevents 

plugging and thereby maintains down-hole pressures at an acceptable level. The 

maximum rate of advance will be set, and periodically adjusted, by the HDD Operator, 

based on consultation with the On-site Mud Engineer, and as subsurface conditions 

change. If plugging occurs (i.e. return flow is diminished relative to fluid pumping rate), 

the rate of advance will be reduced, stopped, or reversed, as appropriate, until the plug 

has been cleared. 

c) Minimum Pump Pressure 

Drilling fluid pump pressure will be maintained at no more than the minimum necessary 

to maintain good circulation and to keep the borehole clear of cuttings. In the event a 

reduction in circulation is observed, at the discretion of the On-site Mud Engineer, 

adjustments to drilling fluid properties (i.e., density, viscosity, etc.), rate of drill head 

advance, and reaming diameter will be considered before pump pressure is increased. 

5.5. Monitoring for Frac-outs 

The HDD Operator will ensure that HDD operations are monitored for the occurrence of 

frac-outs using each of the following methods, where appropriate: 

I-13 Appendix I 
5.5.1. Pump Pressure 

The drilling fluid pump discharge pressure shall be continuously monitored by the Onsite Mud Engineer and recorded on a field data log prior to each joint connection. 

Significant changes or fluctuations in pressure may indicate the possibility of a frac-out, 

requiring immediate response. 

5.5.2. Circulation Rate 

The On-site Mud Engineer shall continuously monitor the flow rate of drilling fluid 

circulation and the volume of returns and record the data prior to each joint connection 

or following a change in return rate. Differences between the pumping rate and the rate 

of returns may indicate a frac-out. 

5.5.3. Ground Surface Inspection 

The HDD Operator shall assign one person to visually inspect the ground surface in 

uplands and marsh along the progress of the HDD for indications of escaping drilling 

fluids. Where possible, without trespassing outside the approved workspace or entering 

marsh (i.e., from a boat adjacent to the marsh), the inspection will cover a corridor 

approximately 500 feet wide, centered on the drill. Inspections shall be made relative to 

the rate of advance of the drill head, but an inspection pass shall be made at least once 

every hour while pumping drilling fluids. Any indications of a frac-out shall be reported 

immediately to the HDD Operator. If operating parameters (i.e., fluctuations in fluid 

pressure or returns) indicate the possibility of a frac-out, the surface inspection shall 

become continuous (daylight only) until the location of the suspected frac-out is found, 

the drill is completed, or measures to remedy the frac-out using additives or other 

operational adjustments have been successful. Daylight continuous monitoring will 

supplement the monitoring of operating parameters. Reasonable efforts will be made to 

locate the point of frac-out, if possible, in order to assess environmental damage, if any. 

Inspections on uplands may be made on foot or from an appropriate vehicle. 

Inspections in marsh may be made on foot or from a boat in adjacent waters, depending 

on the potential for negative impacts to marsh by the inspection activities. Site-specific 

marsh inspection methods shall be reviewed and approved by the On-site KMLP 

Environmental Monitor, following consultation with the regulatory agency representative, 

if present. 

I-14 Appendix I 
5.5.4. Surface Water Inspection 

The HDD Operator shall assign an individual to visually inspect the waterbodies under 

which the HDD is crossing for turbidity plumes that might indicate a frac-out is occurring. 

Inspection passes shall be made at least once every hour while pumping. Any 

indication of a frac-out shall be reported immediately to the HDD Operator. If operating 

parameters indicate the possibility of a frac-out under water, the water inspection shall 

become continuous (daylight only) until the location of the suspected frac-out is found, 

the drill is completed, or measures to remedy the frac-out using additives or other 

operations adjustments have been successful. Inspections shall be made by boat, or 

from an elevated position on land with an unobstructed line-of-sight to the water body 

(binoculars are recommended). Inspection boats shall be positioned and operated so 

as not to interfere with the ability to observe a plume or create a prop-induced plume 

(i.e. down-current from the drill centerline). 

5.5.5. Special Safety Considerations 

Monitoring in water or marsh at night or in fog will require special safety precautions and 

equipment considerations, including Coast Guard-approved navigation lights on all 

vessels, two men in each boat, continuous communication with the onshore crew or the 

drill barge, and portable lights of sufficient power to effectively monitor the area. No 

continuous nighttime monitoring will be allowed. Monitoring in water or marsh will be 

discontinued whenever conditions render the activity unsafe. At such time, the HDD 

Operator will determine, subject to KMLP approval, if drilling can safely continue while 

monitoring for frac-outs based solely on pump pressure and drilling fluids returns. 

5.5.6. Notifications 

Upon first indication of a frac-out, the HDD Operator shall notify the On-site KMLP 

Environmental Monitor. Upon confirmation of a frac-out, the On-site KMLP 

Environmental Monitor will notify the appropriate regulatory agencies, and the HDD 

Operator shall notify the affected landowner(s). 

5.6. Initial Response to a Frac-out 

The HDD Contractor’s initial response to a potential frac-out shall be in accordance with 

the flow diagram provided in Figure 1, and as described in further detail below. 

• Upon first indication of a potential frac-out, the HDD Operator shall reduce 

drilling fluid circulating pressure, continue rotation of the drill string, and 

I-15 Appendix I 
continue to advance the drill head in an attempt to stop or substantially 

reduce the frac-out rate. 

• If the frac-out is initially or subsequently confirmed by an observed release of 

fluids to the surface or an observed turbidity plume in water, the HDD 

Operator will attempt to advance the drill head past the known point of the 

frac-out. 

• Concurrently, the On-site Mud Engineer may inject pre-approved additives, in 

concentrations recommended by the manufacturer and as calculated by the 

On-site Mud Engineer, into the drilling fluid mixture in an additional attempt to 

control the release. 

• If the release of drilling fluids continues unabated at a rate that threatens to 

expand to more than 0.1 acres of marsh habitat, or at a rate otherwise 

deemed excessive by the On-site KMLP Environmental Monitor (in 

consultation with the regulatory agency representative, if present), or 

completion of the drill is in jeopardy due to failure to remove cuttings from the 

borehole, advancement of the drill will be temporarily suspended. 

• The Drill Operator may continue to rotate the drill string in the borehole and 

circulate fluids at a pressure that does not result in continued fluid release at 

the frac-out point, in order to keep the borehole open. 

• If the frac-out is to marsh, the HDD Operator shall request that the On-site 

KMLP Environmental Monitor proceed to the analysis for containment and 

recovery described in Section 5.7.2 below, before continuing with the drill. 

• If the frac-out is to uplands, the HDD Operator may continue advancing the 

drill, provided the released fluids are contained and removed (as described in 

Section 5.7.3 below), and after confirmation that cuttings are being returned 

at a sufficient rate to ensure successful completion of the borehole. The Onsite Mud Engineer shall make adjustments to the drilling fluid properties to 

plug the frac-out or reduce the volume of fluids being released. 

I-16 Appendix I 
Proceed with 

pullback

Figure 1. HDD Frac-out Flow Chart

Reduce circulating pressure (5.6.1)

Advance drill past frac-out (5.6.2)

Mix additives (5.6.3)

Start HDD

Monitor drilling 

fluids circulation

 and ROW (5.5)

Frac-out 

indicators 

observed?

Frac-out indicators:

- pressure changes (5.5.1)

- reduced returns (5.5.2)

- mud discharge to surface (5.5.3)

- turbidity plume (5.5.4)

Drilling 

complete

?

Frac-out 

location?

Upland

Marsh

Open 

water

Yes

No

Yes

No

Obtain landowner 

access 

permission

Contain, remove, 

and dispose mud

(5.7.1, 5.7.3)

Obstructs 

channel, impacts

oysters, 

excessive 

turbidity?

No

Yes

Adjust drilling fluids 

properties to reduce 

volume released 

Sufficient 

returns to 

complete 

hole?

Continue 

 advancing the 

drill (5.6.7, 5.6.8)

Yes

Measure 

impacted area 

(5.7.2)

Estimate additional impact if

drilling continued without 

containment (5.7.2)

Containment 

indicated? 

(Form 1)

Yes

No

No

Stop advancing drill.

Reduce circulating 

pressure.

Continue rotation.

Options 

exhausted

?

No

Abandon hole?

Yes

Characterize 

impacted area 

(5.7.2)

Note: See Frac-Out Procedures 

text for detailed descriptions and 

assigned responsibilities for

each activity. Procedure section 

numbers shown in parentheses.

Compare net impacts 

(5.7.2)

Continue 

drilling

Cease 

operations and 

consult with KM

Excessive 

release? 

(5.6.4)

Stop advancing drill (5.6.4)

Circulate at pressure that results in 

no discharge (5.6.5)

No

Yes

Notify landowner 

and regulatory 

agencies (5.5.6)

Temporarily 

suspend drilling

(5.6.8)

Estimate impacts from

containment activities (5.7.2)

Estimate reduction in impacts if

fluids are contained and removed 

(5.7.2)

Proceed with drill, 

continue to monitor 

(5.7.2)

Drill 

complete

?

No

Proceed with 

pullback

Yes

Frac-out 

stopped?

Continue 

drilling

Yes

No

Frac-out 

stopped, 

reduced, or 

contained?

Yes

No

I-17 Appendix I 
• The HDD Operator may also continue to advance the drill if the release is to 

open water, the release does not obstruct a navigation channel, directly 

impact oyster resources, or accumulate in marsh and the cuttings are being 

returned at a sufficient rate to ensure successful completion of the borehole. 

The On-site Mud Engineer shall make adjustments to the drilling fluid 

properties to plug the frac-out or reduce the volume of fluids being released. 

If, however, the On-site KMLP Environmental Monitor (in consultation with the 

regulatory agency representative, if present) deems the resulting turbidity 

plume to be excessive, the HDD Operator shall temporarily suspend drilling 

until necessary corrective measures are successfully implemented. 

• The On-site Mud Engineer shall record all parameters being tracked at the 

time of frac-out, including fluid circulating pressure, fluid mixture composition, 

fluid viscosity, location and depth of the drill head, location of the frac-out, rate 

of drill advance, and time of day. The HDD Operator shall keep a running log 

of all activities associated with the attempts to control the frac-out. 

5.7. Containment and Removal 

Containment and removal of drilling fluid releases to the surface from a frac-out shall be 

performed where practical and where there will be a net benefit in the reduction of total 

environmental impacts. 

5.7.1. To Surface Waters 

Containment and removal of drilling fluids released to surface waters as a result of a 

frac-out is generally impractical and ineffective because of dilution in the water column, 

and dispersion due to tides and currents. If, however, the On-site KMLP Environmental 

Monitor (in consultation with the regulatory agency representative, if present) considers 

the resulting plume excessive, or the plume may directly and negatively impact oyster 

resources or adjacent marsh, the HDD Operator shall implement the following 

containment measures. 

• Depending upon the depth of water and surface conditions, floating silt 

booms, anchored in place, shall be placed over the location of the frac-out. 

The purpose of the containment is to confine the suspended solids until some 

observable degree of settlement can occur. Removal of the diluted drilling 

fluids is not anticipated, unless dictated by unusual circumstances, and 

subject to KMLP approval. 

I-18 Appendix I 
• The containment shall remain in place until the frac-out stops, and settlement 

renders the turbidity inside the containment similar to the adjacent waters 

based on visual inspection (Secchi disk), or the threat to the sensitive 

resource has passed (e.g. reversal of tidal currents). 

• Any containment structure placed in open water shall be clearly marked as an 

obstruction in accordance with Coast Guard regulations, with special 

consideration given to the type of marine traffic observed in the area. 

5.7.2. In Marsh 

Containment and removal of released drilling fluids from a frac-out to marsh shall be 

performed when there is a net benefit in the reduction of impacts, as determined by the 

following actions. 

• Upon confirmation of a frac-out in marsh, the HDD Operator shall assist the 

On-site KMLP Environmental Monitor in measuring the area directly affected 

by the released drilling fluids. The area affected may be estimated from a 

distance, if access to the affected area for measurement would result in 

additional unacceptable negative impacts. 

• The On-site KMLP Environmental Monitor (a qualified wetlands biologist) will 

characterize the type of impact (e.g., temporary, permanent, vegetation only, 

change in surface hydrology) caused by the released fluids. The On-site 

KMLP Environmental Monitor will seek concurrence from the regulatory 

agency representative, if present. 

• The HDD Operator and the On-site KMLP Environmental Monitor shall jointly 

estimate the additional area, if any, likely to be affected if the drilling were to 

proceed and the drilling fluids were not contained and removed. 

• In consultation with the HDD Operator, the On-site KMLP Environmental 

Monitor will estimate and characterize the additional impacts to marsh likely to 

occur as a result of accessing the affected area for containment and removal 

of the drilling fluids. 

• The On-site KMLP Environmental Monitor will estimate any reduction in 

impacts that might be achieved if the released fluids were removed. 

I-19 Appendix I 
I-20 Appendix I 

• The total actual impacts, plus the estimated impacts from continuation of an 

uncontained release, shall be compared to the total actual impacts, plus the 

estimated impacts from accessing the area for containment and removal, less 

the estimated reduction in impacts as a result of recovery of the fluids. (Use 

Form 1 for guidance.) When making this comparison, some consideration 

and judgment should be given to the types of impacts, and value of the 

resources affected, if dissimilar. The action resulting in the least total impacts 

will generally be selected, unless there are mitigating circumstances, or as 

otherwise instructed by the regulatory agency representative, if present. 

• If the decision is to forgo containment and proceed with the drill, the On-site 

KMLP Environmental Monitor will continue to observe the location of the fracout. If the impacts continue to increase, the On-site KMLP Environmental 

Monitor will periodically repeat the comparison described above, until such 

time as containment and removal are justified, or the drill is complete. 

• In the event of excessive and uncontrolled discharges of drilling fluids to 

marsh, KMLP and the HDD Operator shall determine a course of action. The 

frac-out shall be successfully plugged through adjustments in mud mixture or 

drilling techniques, or the released fluids shall be contained and recovered 

from the marsh with minimal and acceptable levels of impact. [NOTE: No 

containment or recovery activities will be allowed in the marsh without agency 

approval.] If this cannot be achieved, the borehole shall be abandoned. 

• Prior to commencement of any HDD, the HDD Operator shall ensure that 

appropriate equipment is available at each HDD location to contain and 

recover drilling fluid flow from frac-outs into marsh. (See checklist in 

Appendix B.) 

• If it is determined (as described above) that the released drilling fluid is to be 

contained and recovered, the HDD Operator shall direct the placement of the 

equipment at the obvious point or points of frac-out and transfer the contained 

fluids to a hopper barge or frac tank for reuse or disposal. 
I-21 

Form 1. Marsh Frac-out Impacts Comparison 

Drilling Fluids Containment vs. No Containment (to be completed by On-site KMLP Environmen

HDD No.: Date: Frac-out Location: X= Y= Distance from Entry Point (ft) = 

Impact Characterization 

Description Area (Acres) Vegetation Surface Hydrology Comm

No Containment or Recovery Option: Actual marsh area impacted by drilling fluids Temp 

 Perm  None 

 Temp  Perm  None 

Plus estimated additional area impacted if drill proceeds (consider all reduction measures, such as drill head advancing past frac-out, frac-out control additives, reduced pump pressure, etc.) 

 Temp  Perm  None 

 Temp  Perm  None 

Subtotal No Containment or Recovery 

Containment and Recovery Option: Actual marsh area impacted by drilling fluids Temp 

 Perm  None 

 Temp  Perm  None 

Plus estimated impacts from accessing area for containment and recovery 

 Temp  Perm  None 

 Temp  Perm  None 

Less estimated reduction in impacts by removing drilling fluids Temp 

 Perm  None 

 Temp  Perm  None 

Subtotal Containment and Recovery 

Option Selected: Least total acreage impacted Other, explain: Construction (To Be Determined ): KMLP: Agency: 
• All access to the marsh shall be done in such a manner as to cause the least 

impacts to the marsh vegetation and surface hydrology, and only with agency 

approval. Because of site-specific variables, such as distance from open 

water, surface hydrologic conditions, and vegetation cover, the selection of 

the most appropriate access method (e.g., using shallow draft boats, airboats, 

or on foot) must be made on a case-by-case basis, subject to approval by the 

On-site KMLP Environmental Monitor. The least number of personnel and 

equipment necessary to accomplish the task safely and in a timely manner 

shall be deployed into the marsh as described above. 

• Following containment and removal, the HDD Operator shall continue to 

monitor this location for additional releases, and the remainder of the drill for 

new frac-outs, as the drill progresses. 

• Whether or not containment and recovery is performed, all impacts to marsh 

from frac-outs will be measured, assessed, and recorded by the On-site 

KMLP Environmental Monitor, with assistance from the HDD Operator, for 

determination of any mitigation or restoration measures that may be 

necessary, as described below. 

• Upon completion of the boring, the HDD Operator shall ensure that all 

containment and recovery equipment, tools, supplies, materials, wastes, and 

debris are removed from the marsh. 

5.7.3. On Uplands 

• The HDD Operator shall utilize as necessary, the appropriate combination of 

sand bags, hay bales, silt fence, pumps, hoses, and frac tanks that will most 

effectively contain and remove drilling fluids from upland areas (see checklist 

in Appendix B). The HDD Superintendent shall make the determination of the 

equipment and materials to be used, with approval of the On-site KMLP 

Environmental Monitor. 

• The HDD Operator shall instruct the recovery crew to pump the contained 

and recovered fluids to frac tanks on site for reuse, if the On-site Mud 

Engineer determines the fluids are reusable. Otherwise, the fluids will be 

transported off site for disposal. (See HDD procedures for instructions on 

proper transportation and disposal of drilling fluids.) 

I-22 Appendix I 
• KMLP will obtain landowner permission prior to accessing any upland sites for 

fluids containment and removal operations, except in an emergency where 

inaction would pose an imminent threat to human health, sensitive 

environment, or property. 

5.8. Impacts Assessment 

Whether or not the drilling fluids have been successfully contained and removed, the 

On-site KMLP Environmental Monitor will fully characterize the environmental impacts 

from any release of drilling fluids following completion of the HDD, including the areal 

extent of the plume, the area affected by any recovery efforts, the type of marsh and 

vegetation impacted, changes to marsh elevation and hydrology, and whether the 

impacts are permanent or temporary. The On-site KMLP Environmental Monitor will 

seek concurrence of his assessment with the regulatory agency representative, if 

present. 

The HDD Operator will provide an assistant and a boat (if necessary) to assist the Onsite KMLP Environmental Monitor in completing this assessment. 

A report of the assessment will be provided to the regulatory agency representative for 

determination of any further action. 

6. Definition of HDD Failure and Abandonment Criteria 

In the event the mitigation methods identified in Sections 4 and 5 are implemented with 

unsatisfactory results, KMLP will employ the following criteria to determine if the HDD 

method has failed and should be abandoned. If it is determined that HDD has failed, 

the alternative crossing method (or methods) identified in Table 1 will be utilized to 

complete the installation of the pipe. 

6.1. Criteria for Pilot Hole Failure 

Generally, breakdown of the HDD equipment is not considered to be acceptable criteria 

for an HDD failure. If surface HDD equipment, such as the HDD rig, breaks, it is the 

responsibility of the HDD Contractor to repair the equipment within 7 days. If the HDD 

Contractor can not repair the equipment within that time period, a second HDD 

Contractor may be identified and the HDD crossing will be re-started. 

If, according to the HDD Operator, subsurface conditions are such that additional 

attempts at completing the HDD crossing would likely result in continued equipment 

failure, and, in the HDD Operator’s option, the HDD method will not be successful, 

KMLP and the agency will discuss the possibility of abandoning the HDD method. 

I-23 Appendix I 
If drilling equipment breaks in the boring and cannot be retrieved, the HDD Operator will 

attempt to drill around the downhole equipment. If the HDD Operator cannot advance 

the pilot hole, the HDD equipment will be moved to the second, immediately adjacent, 

HDD location, if available (see Table 1), and the HDD Operator will attempt to re-drill 

the pilot hole. If a second HDD location is not available, the HDD as designed will have 

failed, and KMLP will advance to the alternative crossing method (see Table 1). 

If, after adjusting the drilling fluids, the initial pilot hole collapses on the downhole 

equipment or there is a frac-out that meets conditions of failure identified in Section 5, 

the HDD Operator and the On-site KMLP Environmental Monitor will determine if the 

pilot hole can be redesigned to utilize a different subsurface strata and attempt a 

second installation of the pilot hole at the original HDD location. 

If the pilot hole can be redesigned but not installed at the original HDD location or if the 

pilot hole can not be redesigned, the HDD equipment will be moved to the second 

adjacent location, if available (see Table 1), and a pilot hole installation attempt will be 

completed at the second, adjacent HDD location. If the attempt fails at the second HDD 

location, KMLP may consider the HDD as designed a failure. If a second adjacent HDD 

location is not available, the HDD as designed may be considered a failure. 

Failure of the pilot hole installation due to deviation from the designed pathway is not 

anticipated. If the pilot hole deviates from the designed pathway, the HDD operator will 

back out of the borehole, grout the incorrect pathway and re-drill the pilot hole, 

correcting for the pathway deviation as needed. 

Once HDD has been determined to have failed, the HDD Contractor will demobilize its 

equipment from the site after approval from KMLP and the crossing will be completed 

using the alternative method. 

6.2. Criteria for Reaming and Swabbing Failure 

If, following the collapse of the opened borehole or due to stresses on the equipment, 

the reamer equipment fails and part or the entire reamer is lost downhole, the HDD 

Contractor will be allowed 7 working days to attempt to retrieve the equipment from the 

hole and then return to the HDD crossing installation. If the HDD Contractor cannot 

retrieve the lost equipment, this is an unsuccessful attempt at opening the completed 

pilot hole due to equipment failure. If possible, a new pilot hole will be redesigned and 

installed at the first HDD location or if available, installed at the second adjacent HDD 

location. If neither of these two options can be implemented, HDD may be considered a 

failure due to equipment failure. 

I-24 Appendix I 
If the borehole collapses during the reaming process and the reaming equipment is 

retrieved, the pilot hole will be re-drilled at the original location and the pilot hole 

opening re-attempted. If, there is a second unsuccessful attempt at opening the pilot 

hole, the HDD Operator and the On-site KMLP Environmental Monitor will determine if 

the pilot hole can be redesigned and installed at the original location. If not, the HDD 

equipment will be moved to the second adjacent HDD location, if available (see Table 

1), and the HDD Operator will attempt pilot hole installation and conditioning. If there 

are two unsuccessful attempts at opening the pilot hole at the second HDD location, 

HDD may be considered a failure. If there is not a second adjacent HDD location, the 

HDD as designed may be considered a failure. 

Once HDD has been determined to have failed, the HDD Contractor will demobilize its 

equipment from the site after approval from KMLP and the crossing will be completed 

using the alternative method. 

6.3. Criteria for Pullback Failure 

If during the pull back process the pipe becomes stuck in the borehole, the HDD 

Operator will attempt to remove the pipe. If the pipe can be removed, the hole will be 

reconditioned and a second attempt to pullback the pipe will be completed. If during the 

second attempt to pullback the pipe, the pipe again becomes stuck, the HDD Operator 

will attempt to remove the pipe. If the pipe can be removed, the HDD Operator and the 

On-site KMLP Environmental Monitor will determine if a third attempt at the original 

location is warranted or if a new pilot hole should be drilled and opened at the second 

adjacent HDD location, if available (see Table 1). If a third attempt to pull the pipe at 

the original location fails, the HDD equipment will be moved to the second adjacent 

HDD location, if available (see Table 1) and a new pilot hole will be installed and 

opened. If a second HDD location is not available, HDD may be considered a failure. 

If the crossing is moved to the second HDD location, three attempts to pullback the 

pipe, in which the pipe becomes stuck but can be retrieved, will be completed before 

HDD may be considered a failure. 

If during the pullback process the pipe becomes stuck and cannot be retrieved from the 

borehole, the pipe will be abandoned in place. If a second HDD location is available, a 

new pilot hole will be installed and conditioned. A maximum of three attempts at the 

second location to pullback the pipe will be completed before HDD may be considered a 

failure. If a second location is not available, then HDD may be considered a failure. 

I-25 Appendix I 
Once HDD has been determined to have failed, the HDD Contractor will demobilize its 

equipment from the site after approval from KMLP and the crossing will be completed 

using the alternative method. 

7. KMLP/Agency Communication 

The On-site KMLP Environmental Monitor will prepare documentation in the form of 

daily progress reports, as-built information, and a description of the events leading up to 

the HDD failure. This documentation will be presented to the appropriate agencies 

notifying them of the HDD failure and KMLP’s schedule for implementing the approved 

alternative crossing method. Pre-approval of the alternative crossing method will allow 

KMLP to proceed in a timely manner to begin implementation of the alternative method 

without additional agency approval or acknowledgement of the receipt of the failure 

documentation. 

I-26 Appendix I 
Appendix A – MSDS Sheets for Drill Additives 

I-27 Appendix I 
I-28 Appendix I 
I-29 Appendix I 
I-30 Appendix I 
I-31 Appendix I 
I-32 Appendix I 
I-33 Appendix I 
I-34 Appendix I 
I-35 Appendix I 
I-36 Appendix I 
Appendix B – Containment and Recovery Equipment 

Checklist 

Silt fence 500 feet 

Hay bales 50 bales 

Small pumps 2 

Flex-line (2”) pump hose 200 feet 

Aluminum boats 2 

Shovels 6 

I-37 Appendix I 
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