Horizontal Directional Drill Contingency and Frac-Out Response Plan. Harpster-Lima Pipeline Project

Horizontal Directional Drill Contingency and Frac-Out Response Plan Harpster-Lima Pipeline Project March 2016

Horizontal Directional Drill Contingency and Frac-Out Response Plan TABLE OF CONTENTS 1.0 INTRODUCTION... 1 2.0 CONTENT AND UTILIZATION OF DRILLING FLUIDS... 1 3.0 MONITORING, RESPONSE AND CONTAINMENT... 1 3.1 ON-SITE MONITORING DURING CONSTRUCTION... 2 3.2 RESPONSE TO AND CONTAINMENT OF INADVERTENT RELEASES... 3 3.2.1 Minimization of Volume Released... 3 3.2.2 Containment and Control of Drilling Fluid Released... 3 3.2.3 Emergency Response Equipment... 4 3.2.4 Environmentally Sensitive Sites... 4 3.2.5 River Bank and Floodplain Sites... 5 3.3 RECOVERY AND CLEAN-UP OF INADVERTENT RELEASES... 5 3.3.1 Recovery and Clean-Up in Environmentally Sensitive Sites... 5 3.3.2 Recovery and Clean-Up on River Banks and Floodplain Sites... 6 3.3.3 Recover and Clean-Up In Streams... 6 4.0 NOTIFICATION PROCEDURES... 6 5.0 DRILLING MUD DISPOSAL... 7 6.0 RESTORATION AND POST-CONSTRUCTION MONITORING... 7 7.0 DRILL HOLE SEALING... 7 i

1.0 INTRODUCTION During construction of the Harpster-Lima Pipeline Project (Project), Marathon Pipe Line Company LLC (MPL) proposes to cross selected waterbodies, wetlands, roads, and railroads using horizontal directional drilling (HDD) technology. HDD is a widely accepted trenchless construction technique that accomplishes the installation of buried utilities with minimal disturbance to the surface of the right-of-way and the area traversed and therefore little to no environmental impact. HDD is a proven and reliable alternative to standard crossing methods. Although the vast majority of directional drills are accomplished without incident, under certain conditions it is possible that drilling fluids can be inadvertently released to the surface during drilling operations. Such a release is commonly referred to as a fracture or frac-out. MPL has developed a contingency and response plan for the HDDs planned during construction of the Project which is contained herein. This Horizontal Directional Drill Contingency and Frac-Out Response Plan (Plan) describes monitoring, containment, response and notification procedures to be implemented by the contractor, as appropriate, and supervised by MPL. MPL will familiarize the contractor with the Plan and ensure that construction personnel are prepared to respond to an inadvertent release of drilling fluids. 2.0 CONTENT AND UTILIZATION OF DRILLING FLUIDS Drilling fluids typically consist of water and a commerical clay-based additive at an approximate ratio of 95% water and 5% bentonite clay. The commerical clay may also contain 0.1 to 0.5% of an organic polymer for added yield viscosity, suspension, and lubricating ability. Neither the bentonite nor the organic polymer are considered environmentally hazardous materials. Nonetheless, Safety Data Sheets (SDS) will be maintained on-site during drilling operations for all drilling fluid constituents. During drilling operations, water and bentonite will be mixed and pumped through the drill stem to the drill head. The drilling fluid is jetted into the drill hole face to carry drill cuttings out of the hole to a return sump pit. During enlargement of the pilot hole, the drilling mud is continually conditioned for reuse by a process that removes drill cuttings from the fluid. Additional water and bentonite are added to the mixture as needed to replenish the fluid used to maintain the drill hole or lost during separation of the drill cuttings. At the exit point of the HDD, drilling mud is discharged into a sump and then pumped into a holding tank. Excess drilling mud will be disposed of as described in Section 5.0. Drilling fluid is typically inert and as such, does not require treatment prior to disposal. 3.0 MONITORING, RESPONSE AND CONTAINMENT Inadvertent drilling fluid releases could result if the drilling fluid escapes containment at pits excavated at the HDD entrance and exit points or if a frac-out occurs. In many cases, a loss of drilling fluid circulation is the result of drilling fluid dispersing into surrounding soils, entering geological seams, fissures and fractures during drilling of the pilot hole. Consequently, the loss of drilling fluid pressure does not necessarily mean that an inadvertent release of fluid (i.e., a frac-out) to the surface has occurred or will occur. Frac-outs occur most often in highly permeable soils during the entrance and exit phases of the pilot hole drill, as this is when the greatest pressures are exerted on the bore walls in shallow soils. 1

To minimize HDD failure and/or frac-out risks, and to be best prepared to handle them should they occur, the HDD Contractor may work certain HDD operations twenty-four (24) hours a day using two (2), twelve (12) hours shifts per day. This gives the HDD Contractor the greatest chance of maintaining the borehole integrity and successfully pulling the pipe into place while minimizing the risks of drill string seizing, hole collapse, or inadvertent returns. The monitoring, response and containment procedures described below will be implemented in order to mitigate inadverent drilling fluid releases that may occur during HDD operations. These procedures provide a system to control and minimize the effects of such a release, should one occur. Importantly, potential environmental impacts can often be minimized by completing construction quickly. By adding a sealing media to the drilling fluid and completing the drill as quickly as possible, the amount of fluid released can be minimized. The only alternative to this approach would involve attempting a second drill at a different location, which could result in another release and additional environmental impact. Therefore, absent a threat to public health and safety and/or significant impacts to sensitive environmental resources, drilling operations will typically continue in the event of the loss of circulation. MPL s Plan provides the contractor with a systematic approach to control, clean-up and dispose of drilling mud, as well as an inventory of equipment and supplies that will be available during drilling operations. MPL will ensure that copies of plans are on-site and available for contractor personnel and environmental inspectors (EIs) at HDD worksites. 3.1 On-Site Monitoring During Construction Drilling fluid pressures in the bore hole and drilling fluid pumping and return rates and volumes will be monitored to detect the potential occurrence of a frac-out or loss of drilling fluid. If survey and monitoring procedures indicate that a frac-out may have occurred, the drilling contractor would cease pumping and implement the processes detailed in this contingency plan. A monitor will be on site continuously during drilling activities to visually search for observable fracout conditions. The HDD contractor will keep the monitor apprised of the drill fluid release pressures and mud volume balance and will provide their professional opinion of level of risk of a frac-out occurring at any given time. Contract personnel involved in monitoring activities will typically be craft foremen, environmental inspectors (EIs), and craft inspectors. MPL personnel who will also be periodically on-site typically include the Chief Inspector, project engineers, land representatives, and project environmental representatives. Contractor and MPL personnel will have appropriate, operational communication equipment (e.g., radios and cellular phones) available at all times during HDD operations and will have direct communication with the HDD operations control center. The contractor will have readily available containment equipment to contain inadvertent releases of drilling mud, see representative list of equipment in Section 3.2.3. The EIs will ensure that adequate quantities of spill containment equipment and supplies are at the drilling location prior to allowing the contractor to begin drilling. Further, the EIs will ensure that each individual involved in drilling operations is familiar with the locations of all spill containment equipment and the specific procedures for handling potential drilling fluid releases. As stated above, drilling activities may be conducted 24 hours per day to provide the greatest chance of maintaining the borehole integrity and success in pulling the pipe into place. In this regard, floodlights will be utilized to illuminate night-time drilling operations and enable inadvertent return 2

monitoring. In addition, the HDD contractor will monitor for any decrease in pressure readings. If decreased pressures are observed, the drilling mud may be escaping into the soil layer or through fractures in the soil. If a drilling mud leak is identified, an attempt will be made to advance the drill head past the known point of the frac-out. The pressure of water/soil above the borehole will tend to resist mud escaping through the fracture. The amount of drilling mud that could be lost to the environment in the event of an inadvertent return depends on the size of the fracture and amount of head pressure. Because there will be a monitor continuously carrying out visual inspections along the drill path, fluid return pit(s), and wetland/waterbody surfaces for evidence of a release on the site at all times, the amount of escaping mud is expected to be kept to a minimum. 3.2 Response To and Containment of Inadvertent Releases Upon first indication of a frac-out, the HDD Contractor shall notify MPL personnel in accordance with the procedures outlined in Section 4.0. Upon frac-out confirmation, MPL will immediately notify regulatory agencies as appropriate and coordinate with the agencies regarding a suitable course of action. MPL Land Agents will notify any affected landowners. 3.2.1 Minimization of Volume Released The first action required when a frac-out is detected is to minimize the volume of drilling fluid that is released. The HDD contractor shall reduce drilling fluid circulating pressure, continue rotation of the drill string, and continue to advance the drill head in an attempt to stop or substantially reduce the frac-out rate. If the frac-out is intially or subsequently confirmed by an observed fluid release to the surface or turbidity plume in water, the HDD contractor will attempt to advance the drill head past the known frac-out point. If the HDD contractor determines that sealing of a fissure within the substrate is necessary, the contractor may use a plug or pill. The plug may consist of material that has a granular, flake, or fibrous structure (e.g., ground walnuts, pecans, etc.). 3.2.2 Containment and Control of Drilling Fluid Released In the event of an inadverent driling fluid release, the contractor s activity foreman, the EI, and the chief activity inspector will acesss the amount and location of the release. This team will evaluate the potential risk that the release may pose to aquatic or other environmentally sensitive resources and possible control measures, and will respond as described below: Evaluate the release; estimate the volume and rate of discharge, and determine if containment structures are warranted. If necessary, MPL will ensure that the contractor installs containment devices (e.g., silt fence and/or staked straw bales) to prevent movement of drilling mud off-site or toward a waterbody. The contractor may simultaneously recover and remove fluid as the release is occurring. For larger releases where there is a potential impact to aquatic or other environmentally sensitive resources, the contractor s activity foreman and/or environmental foreman and the EI will consider the installation of collection sumps in conjunction with sediment barriers. Remedial action to establish circulation may be initiated. Remedial action may include, but will not be limited to, sizing the hole to remove annular obstruction, reducing pumping rates, and/or modifying drilling mud properties. 3

Drilling operations will not be suspended unless the release poses a threat to public health and safety and/or significant impacts to sensitive environmental resources. Comply with standard notification procedures listed in Section 4.0. Identify clean-up parameters and monitor clean-up and recovery activities. For each inadvertent release, the EI will complete an Environmental Inspection Report Form. 3.2.3 Emergency Response Equipment Containment, response, and clean-up equipment will be available at the HDD location to assure a timely response. Equipment may include, but is not limited to: earth moving equipment hay or straw bales and stakes silt fence, T-bar posts, post pounders plastic sheeting or geotextile fabric sediment curtains shovels, push brooms, squeegees, trowels, pails pumps with sufficient leak-free hose and suction heads mud storage tanks vacuum truck (on 24-hour call) light plant/generator, lights and towers, electrical cords extra radio, cellular phone(s), batteries, flashlights, lanterns boat (approximately 16 feet-long) with oars or outboard motor SDS sheets for on-site materials 3.2.4 Environmentally Sensitive Sites If a drilling mud release is observed within or adjacent to an environmentally sensitive area (e.g., stream or wetland), MPL and the contractor shall comply with the following procedures in addition to those listed in Section 3.2: If necessary, MPL will install containment interception devices (e.g., silt fence, staked straw bales, and/or sediment curtains) to prevent movement of drilling mud. Installation of the containment devices should be down slope from the release and upslope from the environmentally sensitive area, if possible. If the drilling mud release presents a threat to the aquatic environment (wetland or waterbody), collection sumps will be installed. Collection sumps should be located downslope from the release and outside of any water of the U.S., thus avoiding potential impacts to the environmentally sensitive area(s). No sumps will be excavated within the boundaries of culturally sensitive areas unless approved in advance by the Ohio Historic Preservation Office (OHPO). After drilling and installation of the pipeline are completed, the site will be cleaned up as stated in Section 3.3.1 of this Plan. 4

3.2.5 River Bank and Floodplain Sites If a drilling mud release is observed on a river bank where a direct conveyance to a water body exists, MPL and the contractor will install, if necessary: containment structures (e.g., silt fence or staked straw bales) upslope from the water s edge; and/or collection sumps After drilling and installation of the pipeline are completed, the site will be cleaned up as stated in Section 3.3.2 of this Plan. 3.3 Recovery and Clean-Up of Inadvertent Releases The decision to initiate immediate recovery or to delay the clean-up effort will rest with the Project Manager and Chief Inspector along with the project environmental representatives. These individuals along with the lead EI will determine if physical disturbance of the site during clean-up will result in greater environmental damage than would occur if the drilling mud were to remain temporarily in place. Each decision will be based on site-specific field conditions. Clean-up and recovery may involve one or more of the following measures depending on the volume and location of the release: Small volumes of drilling mud will be cleaned up by hand, using hand shovels, trowels, buckets, squeegees, or soft-bristled brooms. In the case of large releases, a vacuum truck and associated equipment may be used to recover the drilling mud. Drilling mud will be collected and taken to the approval disposal site (see to Section 5.0). Caution will be used to minimize the damage to vegetation. Fresh water washes to remove residue from vegetation may also be applied if deemed beneficial and feasible. Containment structures will be pumped out and the ground surface scraped to bare soil. Drilling mud will be collected and taken to the approved disposal location or site. Care will be taken to minimize undue loss of topsoil or ancillary damage to adjacent vegetation and root structures. Excess material may be collected and temporarily stored in containers at the drill site prior to removal from the site. If clean-up and recovery activities are determined to be environmentally damaging and exceed the benefits of recovery, the EI in charge of clean-up will have the authority to abbreviate recovery activities. 3.3.1 Recovery and Clean-Up in Environmentally Sensitive Sites Removal of drilling mud releases from environmentally sensitive sites will be completed by implementing the procedures described in Section 3.3, and performing the following: The removal of small volumes of mud from the soil surface will be completed by hand. Disturbance to the soil surface will be kept to a minimum. 5

For inadvertent releases in culturally sensitive areas where heavy equipment or mechanical means will be used for recovery, MPL will consult with the OHPO to develop an appropriate strategy to recover drilling mud to minimize rutting and surface disturbance, and to protect the integrity of the site. 3.3.2 Recovery and Clean-Up on River Banks and Floodplain Sites Recovery of drilling mud releases from sites with a direct conveyance to a river bank or floodplain will be completed by implementing the procedures described in Section 3.3, and: If the amount of the surface release is not great enough to allow the practical physical collection from the affected area, it shall be allowed to dry and dissipate naturally. For larger releases, material contained by sediment barriers will be removed either by hand or mechanically and disposed of as describe in Section 5.0 of this Plan. 3.3.3 Recover and Clean-Up In Streams In-stream clean-up measures will be evaluated based on the extent and accessibility of the accumulated residue and the potential environmental effects associated with clean-up operations. In most cases, recovery and clean-up of drilling mud inadvertently released into flowing water will not be practical as recovery measures have potentially greater impact to the environment than allowing the inert, water soluble drilling mud to dissipate naturally. 4.0 NOTIFICATION PROCEDURES The general notification procedure for drilling mud releases during a HDD operation will include the following: Contractor personnel or the environmental foreman will notify the EI or lead EI that a surface release has occurred. The EI or lead EI will inspect the site, complete an Environmental Inspection Report Form and notify the Project Manager, Chief Inspector, and project environmental representatives. Project environmental representatives will be responsible for timely contacting appropriate regulators and resource agencies after detection of a release. If notifications are necessary during non-business hours, voice messages will be left, and the requirements of this Plan will be implemented. Follow-up notifications will be made as soon as practicable on the next business day. If the release is located outside the boundaries of the construction right-of-way, MPL land representatives will be contacted prior to initiating containment and clean-up if practical; however, efforts to contact MPL land representatives shall not unnecessarily delay prompt action to initiate appropriate responses. In the event a release occurs in a water body/wetland, or is discharged directly into a water body, the following procedures will apply: Project environmental representatives will notify the appropriate state fishery resource and/or water regulatory agency with the date, time, location, duration, estimated amount of the 6

release, and corrective actions implemented. MPL will document the notification by submitting a notification to the ALIRTS and/or MAPLINE systems as appropriate. In the event a release occurs in a culturally sensitive area, the following procedures will apply: The EI or lead EI will notify the Project Manager, Chief Inspector and project environmental representative of the date, time, location, duration, estimated amount of the release, and containment alternatives. MPL will notify OHPO of the release date, time, location, duration, estimated amount of the release, and proposed containment recovery activities. After clean-up and recovery of drilling mud, the following notification procedures will apply: The EI will notify MPL project personnel that the clean-up has been completed and project environmental representatives will contact regulatory and resource agencies as soon as possible, and within 24 hours, after completion of the clean-up. 5.0 DRILLING MUD DISPOSAL Upon completion of the HDD, drilling mud and drill cuttings may be temporarily stored on-site in trucks, frac tanks, or in sumps prior to final disposal. The following are two potential methods for final disposal: Where allowed by federal, state, and local regulations, drilling mud may be spread on an upland site near the right-of-way as approved by the landowner. If necessary, topsoil will be stripped and segregated from subsoil prior to spreading drilling mud on the site. Drilling mud will be allowed to dry and will be tiled into the soil. Segregated topsoil will be replaced after the drilling mud is worked into the subsoil. When landowner approval or an appropriate upland site is not available, the alternate disposal method will be to transport the drilling mud to an approved off-site disposal location. 6.0 RESTORATION AND POST-CONSTRUCTION MONITORING Following clean-up, restoration activities will be implemented in accordance with the project s Storm Water Pollution Prevention Plan (SWPPP). 7.0 DRILL HOLE SEALING If a HDD drill hole is abandoned, the drill hole will be sealed to prevent further complications associated with changes in subsurface hydrology or subsidence of the ground surface. The contractor will seal the entrance hole to a depth that provides for safer operational abandonment when the HDD is ended. The entrance hole will be sealed with a material such as sand/concrete slurry, or a mix of drill returns that will provide surface support. Length and volume of the seal will be determined onsite, and will depend primarily on soil conditions, angle of the drill hole, and land use. 7