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    APPENDIX G

    Contingency Plan for Directional Drilling

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    CONTENTS

    1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

    2.0 DIRECTIONALDRILLINGMETHODS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

    2.1 Workspace . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

    2.2 Drilling Fluid and Drilling Fluid System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

    2.3 Pilot Hole . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

    2.4 Reaming Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

    2.5 Pull Back Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

    3.0DRILLING FLUID SEEPAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

    3.1 Prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

    3.1.1 Suitable Material and Adequate Overburden . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

    3.1.2 Pipeline Geometry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

    3.1.3 Responsibility of Drilling Contractor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2

    3.1.4 Detection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2

    3.2 Corrective Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3

    3.3 Follow-up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3

    3.4 Response Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4

    4.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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    Plan of Development, App. G - Contingency Plan for Directional

    Drilling

    January 19, 2000

    Timberline Pipeline Project

    Page 2-1

    1.0 INTRODUCTION

    As part of the Timberline Pipeline Project, Kern River plans to construct approximately 82 miles of pipeline to transport

    natural gas from production areas near Price, Utah to an interconnect with the existing Kern River pipeline west of

    Nephi, Utah. The proposed route of the pipeline involves crossing a number of streams. Kern River intends to utilize

    the directional drilling process to drill underneath at least one of the streams, Salt Creek at MP 64.8, rather than utilizing

    open-trench methods. The directional drilling method was chosen because there are a number of obstacles at this pointincluding Salt Creek, the Mt. Nebo Loop Road and an old dam. Directional drilling is environmentally friendly and has

    been proven to be a safe and efficient method for crossing rivers and streams. The purpose of this plan is to aid Kern

    River in developing a program designed to:

    Eliminate or minimize adverse effects from directional drilling fluid seepage.

    Develop procedures for properly responding to a pipe lodging and separation.

    A brief description of the directional drilling method is presented to provide the backdrop for

    discussing contingency plans.

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    Plan of Development, App. G - Contingency Plan for Directional

    Drilling

    January 19, 2000

    Timberline Pipeline Project

    Page 2-1

    2.0 DIRECTIONAL DRILLING METHODS

    2.1 Workspace

    Temporary workspace areas for the directional drilled crossing will be required on both the entry side

    (rig side) and the exit side (pipe side) of the stream. The entry side workspace will be approximately150 feet wide by 200 feet long and will contain the majority of the equipment required to complete

    the crossing. The exit side workspace will be approximately 150 feet wide by 500 feet long and will

    be primarily used for removing and adding joints of drill pipe as the entry side rig progresses through

    or pulls out of the borehole. The crossing pipe will be welded and stored on the exit side until it is

    pulled into the completed borehole. Typically there are two pits on the entry side: the entry pit and

    the cutting settlement pit. On the exit side there are typically one or two pits. The pit sizes vary

    considerably from job to job; however, an average size would be 20 feet long by 10 to 20 feet wide

    by 5 to 10 feet deep. Project specifications require working pits to be lined with an impervious,

    flexible membrane liner.

    1.2 Drilling Fluid and Drilling Fluid System

    The directional drilling process involves a drilling fluid made up primarily of water and clay. The

    primary purposes of this drilling fluid are to remove the cuttings from the borehole, to stabilize the

    borehole and to act as a coolant and lubricant during the drilling process. The water and clay drilling

    fluid consists of 1 to 5 percent active clays, 0 to 40 percent inert solids, and water. The primary

    active clay component is bentonite. Bentonite is a naturally occurring, non-hazardous clay product.

    A Material Safety Data Sheet (MSDS) for the typical material as taken from Fisher Scientificis

    included as Attachment 1.

    The directional drilling operation involves the continuous flow of drilling fluid into the borehole,

    to lubricate the drill stem and cutters, carry away cuttings, and assist in maintaining hole integrity.The drilling fluid is first prepared in mixing tanks with both new and clean, recycled drilling fluid.

    The fluid is pumped at rates of 100 to 1000 gallons per minute (gpm) through the center of the drill

    pipe to the cutters. Return flow is through the annulus, created by the space between the borehole

    and the drill pipe. The cuttings are then carried back to the entry pit which will be lined with an

    impervious, flexible membrane. Once in the entry pit, the fluid moves into the cutting settlement

    pit and is then pumped into the fluid processing equipment. Shaker screens, desanders, desilters and

    centrifuges remove increasingly fine cuttings from the drilling fluid. The cleaned and recycled fluid

    is returned to the mixing tank and pumps for reuse in the borehole. The volume of cuttings per

    crossing will range from an estimated 4400 cubic feet (163 cubic yards) to 7225 cubic feet (268

    cubic yards), depending on the length of the crossing. These cuttings will be placed in a company-

    approved landfill.

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    Plan of Development, App. G - Contingency Plan for Directional

    Drilling

    January 19, 2000

    Timberline Pipeline Project

    Page 2-2

    2.3 Pilot Hole

    Directional drilling installation within clay, silt, sand, and gravel materials are typically

    accomplished using conventional drilling and hole reaming methods. The pilot hole drilling process

    uses a non-rotating small-diameter (2 to 4 inch) drill pipe thrusting a jetting assembly or motorized

    drilling bit (5 to 9 inch) along the designed drill path. A larger diameter drill pipe (6 to 10 inchdiameter) is used as a wash pipe for the small drill stem. As the pilot hole drilling progresses, the

    wash pipe is rotated and thrust concentrically over the drill stem. The use of the wash pipe facilitates

    movement of the small drill stem and allows retrieval of the drilling and guidance systems for

    maintenance purposes without substantial collapse of drilled pilot hole. The bentonite-based drilling

    fluid is continuously pumped downhole through the drill stem to power the drill motor, remove

    cuttings, and lubricate the working assemblies.

    2.4 Reaming Operation

    Once the pilot hole drilling process has been completed, the drill stem is withdrawn leaving only the

    wash pipe within the drilled hole. Depending upon the type of pipe used, it may be necessary toreplace the wash pipe with high strength drill pipe before continuing with hole reaming. To enlarge

    the pilot hole, specialized cutters and reamers are attached to the drill pipe. The drilling rig then

    rotates the reaming assembly with the drill pipe and guides the reamers along the drilled path.

    Bentonite drilling fluid is continuously pumped through the borehole, as the reamers are rotated

    toward the exit side, to remove the cutaway material. One or more reaming passes through the

    borehole are usually made to achieve the required borehole size.

    2.5 Pull Back Operation

    When the appropriate reaming passes have been completed, the prefabricated pull section is attachedto the drill pipe by means of a swivel assembly. A cutter or reamer is usually placed between the

    drill pipe and the swivel. As the crossing pipeline section is pulled into the reamed hole by the drill

    rig, the reamer is rotated with the drill pipe, and drilling fluid is pumped continuously to evacuate

    cuttings and lubricate the pull section.

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    Plan of Development, App. G - Contingency Plan for Directional Drilling January 19, 2000

    Timberline Pipeline Project Page 3-1

    3.0 DRILLING FLUID SEEPAGE

    3.1 Prevention

    Directional drilling is an increasingly popular method of installation whereby waterway

    disturbance is minimized or eliminated altogether. Directional drilling installation doeshowever present a remote potential for waterway disturbance through drilling fluid seepage.

    Drilling fluid seepage can be caused by pressurization of the drill hole beyond the

    containment capability of the overburden soil material. This potential can be substantially

    reduced by providing adequate depth of cover for the installation.

    3.1.1 Suitable Material and Adequate Overburden

    In the contingency planning for the stream crossings of the Timberline project, prevention

    of drilling fluid seepage will be a primary consideration in determining the profile of each

    crossing. The primary factors in selecting the pipeline crossing profile are the type of soil

    material and the depth of cover material. Cohesive soils, such as clays, are considered idealmaterial for horizontal drilling. Careful evaluation of the subsurface strata of each proposed

    stream crossing, will be completed determine suitability of the soil material for directional

    drilling. The second factor to be considered in developing a profile is adequate overburden

    material. A minimum depth of cover of fifteen feet in competent soils should be maintained

    to provide a margin of safety against drilling fluid seepage.

    As the drill and hole opening assembly nears the ground surface on either side of the river,

    it passes through the area that presents some potential for drilling fluid seepage. Since

    prevention is the best and most effective contingency plan, steps (see paragraph 3.3) have

    been taken to reduce the potential for seepage in these areas. At the exit point, an exit pit can

    be constructed. The exit pit will allow the pipeline to terminate below the surface of theground, so a greater cover or overburden material depth will be maintained to prevent

    seepage. If seepage does occur, it will be more easily detected because the seepage will be

    on land rather than under water. Subsequent containment of the mud can therefore be

    planned and managed. Containment dikes in the form of berms and hay bales will contain

    any seepage and minimize any migration of the mud from the work area.

    3.1.2 Pipeline Geometry

    The geometry of the pipeline profile can also affect the potential for drilling fluid seepage.

    In a profile which forces the pipe to make compound or tight radii turns, downhole pressures

    can build up, thereby increasing the potential for drilling fluid seepage. The profiles for the

    stream crossings on the Timberline Pipeline Project will avoid this potential to the extent

    possible, as they will be designed to be very smooth and gradual vertical curves. In addition,

    horizontal curves will be minimized or eliminated. Therefore, the potential for pressure

    buildup caused by pipeline geometry will be minimized.

    3.1.3 Responsibility of Drilling Contractor

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    Plan of Development, App. G - Contingency Plan for Directional Drilling January 19, 2000

    Timberline Pipeline Project Page 3-2

    The drilling contractor is responsible for execution of the directional drilling operation,

    including actions for detecting and controlling drilling fluid seepage. The progress and

    actions of the drilling contractor will be closely supervised by Williams Chief Inspector and

    their delegated deputies.

    2.0.4 Detection

    Detection of a drilling fluid seepage includes identifying those conditions that may indicate

    a loss of pressure containment within the drill hole, thereby creating the potential for a

    drilling fluid seepage. It also will include those visible signs that surface seepage has

    occurred.

    Directional drilling is a technically advanced process. The detection of drilling fluid seepage

    prior to it occurring is highly dependent upon the skills and experience of the drilling crew.

    Each drilling situation is unique in that the behavior of the subsurface material is highly

    variable and difficult to predict. There is no in-hole monitoring equipment that can detect

    drilling fluid seepage. It is a combination of factors that must be properly interpreted, that

    may indicate conditions which can have the potential of causing drilling fluid seepage.

    A seep occurs when there is a failure to maintain pressure in the hole. The most obvious

    signs of a drilling fluid seepage are surface seepage or loss of drilling fluid circulation. One

    of the functions of the drilling fluid is to seal the hole to maintain the downhole pressure, and

    the loss of returning drilling fluid is a sign that pressure is not being contained in the drillhole

    and seepage is occurring outside of the hole. If there is a reduction in the quantity of drilling

    fluid returning to the drilling site (loss of circulation), this could be a warning sign.

    However, some loss of drilling fluid is also normal in the drilling process. There can be

    times in the drilling process that a loose sand or gravel layer is encountered. Both of these

    conditions will require additional drilling fluids or the introduction of "lost circulation

    materials" (LCM) such as cedar chips to fill in the voids. Consequently, drilling fluid lossin and of itself is not an indication of a potential seepage condition. It is a loss of drilling

    fluid in combination with other factors that may indicate a potential seepage condition. For

    example, if there is a loss of drilling fluid and the return cuttings do not show a large quantity

    of gravel, then this could indicate a loss of containment pressure within the hole.

    Again, the detection of a potential seep prior to it actually occurring is dependent upon the

    skill and experience of the drilling crew. It is for this reason that Kern River will be using

    a firm that specializes in directional drilling to perform the proposed stream crossing. The

    selection and supervision of this drilling contractor will be the responsibility of Williams,

    assisted by their directional-drilling inspectors.

    3.2 Corrective Action

    Once surface seepage of drilling fluid is detected, the drilling crew will take immediate

    corrective action. The only pressure causing the surface seepage to occur is the pressure

    from the drilling fluid pumps. Therefore, the most direct corrective action is to stop the rig

    pumps. By stopping the pumps, the pressure in the hole will quickly bleed off. With no

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    Plan of Development, App. G - Contingency Plan for Directional Drilling January 19, 2000

    Timberline Pipeline Project Page 3-3

    pressure in the hole, the surface seepage will stop. Stopping the pumps will be done as soon

    as surface seepage is detected.

    If seepage occurs in the stream, there may be a visible plume. Minor seepage may be

    difficult to detect due to the turbidity of the water and the high specific gravity of bentonite

    clay drilling fluid. Once seepage is detected and, with the immediate stopping of the mudpumps, there should be minimal disturbance to surface sediment. As mentioned previously,

    there will be very little pressure to disturb surface sediment because of the distance that the

    drilling fluid must travel to reach the surface. The composition of the drilling fluid is

    primarily water and bentonite clay. If a small amount is released into the stream, it is usually

    dissipated quickly by the streams currents.

    There is a greater potential for drilling fluid seepage at the entry and exit locations of each

    crossing than along the length of the borehole. In the contingency planning for the pipeline

    crossing, drilling fluid seepage at the entry and exit locations has been considered, and

    preventative actions have been developed. The entry and exit locations of all directionally

    drilled crossings will have dry land segments where drilling fluid seepage can be easilydetected and contained. To isolate and contain potential drilling fluid seepage at each of the

    drill sites, a berm will be constructed around the entire drilling site. Certified weed-free

    straw/hay bales or silt screen could be incorporated into berm construction and placed on the

    water side of the drilling area. To contain and control drilling fluid seepage on the land area,

    there will be earth moving equipment, portable pumps, sand, and hay bales available at each

    of the drilling sites. Any drilling fluid seepage will first be contained and isolated using dirt

    berms, hay bales or silt screens. It will then be immediately cleaned up from the area and

    hauled to one of the storage pits at the closest drilling site.

    3.3 Follow-up

    If drilling fluid seepage should occur, the drilling operation will be stopped. After the

    drilling fluid seepage has been contained and disposed of, the drilling contractor and Kern

    River will make every effort to determine why the seepage occurred. Once Kern River has

    determined the cause of the seepage, measures will be developed to control the factors

    causing the seepage and to minimize the chance of seepage recurrence. In no case will Kern

    River resume drilling operation until it has determined the cause of the drilling fluid seepage

    and instituted preventative measures.

    In some cases, the corrective measure may involve a determination that the existing hole

    encountered a void which could be bypassed with a slight change in the profile. In other

    cases, it may be determined that the existing hole encountered a zone of unsatisfactory soil

    material and the hole will have to be abandoned. If the hole is abandoned, it will be filled

    with drilling cement.

    3.4 Response Equipment

    From the day-to-day operation and maintenance routine, drilling personnel will be aware

    of what materials are critical during a drilling fluid seepage and will have those

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    Plan of Development, App. G - Contingency Plan for Directional Drilling January 19, 2000

    Timberline Pipeline Project Page 3-4

    containment items on hand. Since drilling fluid seepage can be easily controlled on land,

    where it has the greatest potential of occurring, containment items will be stored within

    the drilling sites and will include materials such as lumber for temporary shoring, sand,

    portable pumps, hand tools and hay bales. The drilling contractor will also have heavy

    equipment such as backhoes that can be used to control and clean up drilling fluid

    seepage.

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    occasionally lifting the upper and lower lids. Get medical aid.

    Skin: Flush skin with plenty of soap and water for at least 15

    minutes while removing contaminated clothing and shoes. Get medical

    aid if irritation develops or persists.

    Ingestion: If victim is conscious and alert, give 2-4 cupfuls of

    milk or water. Never give anything by mouth to an unconscious

    person. Get medical aid.Inhalation: Remove from exposure to fresh air immediately. Get

    medical aid if cough or other symptoms appear.

    Notes to Physician: Treat symptomatically and supportively.

    Section 5 - Firefighting Measures

    General Information: As in any fire, wear a self-contained breathing

    apparatus in pressure-demand, MSHA/NIOSH (approved or equivalent),

    and full protective gear.

    Extinguishing Media: For small fires, use water spray, dry chemical,

    carbon dioxide or chemical foam.

    Autoignition Temperature: Not applicable.

    Flash Point: Not applicable.NFPA Rating: Not published. Explosion Limits, Lower: Not available.

    Upper: Not available.

    Section 6 - Accidental Release Measures

    General Information: Use proper personal protective equipment as

    indicated in Section 8.

    Spills/Leaks: Vacuum or sweep up material and place into a suitable

    disposal container. Avoid generating dusty conditions.

    Section 7 - Handling and Storage

    Handling: Use with adequate ventilation. Avoid contact with skin andeyes. Avoid ingestion and inhalation.

    Storage: Store in a cool, dry place. Store in a tightly closed

    container.

    Section 8 - Exposure Controls, Personal Protection

    Engineering Controls: Use adequate ventilation to keep airborne

    concentrations low.

    Exposure Limits Chemical Name ACGIH NIOSH OSHA - Final PELs

    BENTONITE none listed none listed none listed

    OSHA Vacated PELs: BENTONITE: No OSHA Vacated PELs are listed forthis chemical.

    Personal Protective Equipment

    Eyes: Wear appropriate protective eyeglasses or chemical safety

    goggles as described by OSHA's eye and face protection regulations

    in 29 CFR 1910.133 or European Standard EN166.

    Skin: Wear appropriate gloves to prevent skin exposure.

    Clothing: Wear appropriate protective clothing to minimize contact

    with skin.

    Respirators: Follow the OSHA respirator regulations found in 29CFR

    1910.134 or European Standard EN 149. Always use a NIOSH or European

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    Standard EN 149 approved respirator when necessary.

    Section 9 - Physical and Chemical Properties

    Physical State: Solid

    Appearance: cream

    Odor: odorless pH: Not available.

    Vapor Pressure: Not available.

    Vapor Density: Not available.

    Evaporation Rate:

    Viscosity: Not available.

    Boiling Point: Not available.

    Freezing/Melting Point:Not available.

    Decomposition Temperature:Not available.

    Solubility: Insoluble in water.

    Specific Gravity/Density:Not available.

    Molecular Formula:Not applicable.

    Molecular Weight:

    Section 10 - Stability and Reactivity

    Chemical Stability: Stable under normal temperatures and pressures.

    Conditions to Avoid: Moisture.

    Incompatibilities with Other Materials: None reported.

    Hazardous Decomposition Products: Irritating and toxic fumes and

    gases.

    Hazardous Polymerization: Has not been reported.

    Section 11 - Toxicological Information

    RTECS#:

    CAS# 1302-78-9: CT9450000

    LD50/LC50:

    Not available.

    Carcinogenicity:

    CAS# 1302-78-9: Not listed by ACGIH, IARC, NIOSH, NTP, or OSHA.

    Epidemiology: Experimental tumorigenic data has been reported.

    Teratogenicity: No data available.

    Reproductive Effects: No data available.

    Neurotoxicity: No data available.

    Mutagenicity: No data available.Other Studies: No data available.

    Section 12 - Ecological Information

    Ecotoxicity: Not available.

    Environmental Fate: Not available.

    Physical/Chemical: Not available.

    Other: Not available.

    Section 13 - Disposal Considerations

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    Dispose of in a manner consistent with federal, state, and local

    regulations.

    RCRA D-Series Maximum Concentration of Contaminants: None listed.

    RCRA D-Series Chronic Toxicity Reference Levels: None listed.

    RCRA F-Series: None listed.

    RCRA P-Series: None listed. RCRA U-Series: None listed.

    Section 14 - Regulatory Information

    US FEDERAL

    TSCA

    CAS# 1302-78-9 is listed on the TSCA inventory.

    Health & Safety Reporting List

    None of the chemicals are on the Health & Safety Reporting List.

    Chemical Test Rules None of the chemicals in this product are under a Chemical Test

    Rule.

    Section 12b

    None of the chemicals are listed under TSCA Section 12b.

    TSCA Significant New Use Rule

    None of the chemicals in this material have a SNUR under TSCA.

    SARA

    Section 302 (RQ)

    None of the chemicals in this material have an RQ.

    Section 302 (TPQ)

    None of the chemicals in this product have a TPQ.

    Section 313 No chemicals are reportable under Section 313.

    Clean Air Act:

    This material does not contain any hazardous air pollutants. This

    material does not contain any Class 1 Ozone depletors. This material

    does not contain any Class 2 Ozone depletors.

    Clean Water Act:

    None of the chemicals in this product are listed as Hazardous

    Substances under the CWA. None of the chemicals in this product are

    listed as Priority Pollutants under the CWA. None of the chemicals

    in this product are listed as Toxic Pollutants under the CWA.

    OSHA:

    None of the chemicals in this product are considered highly

    hazardous by OSHA.STATE

    CAS# 1302-78-9 is not present on state lists from CA, PA, MN, MA,

    FL, or NJ.

    California No Significant Risk Level: None of the chemicals in this

    product are listed. European/International Regulations

    European Labeling in Accordance with EC Directives

    Hazard Symbols:

    Not available.

    Risk Phrases:

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