TRANSCANADA

KEYSTONE PIPELINE PROJECT – EXECUTION PHASE

HDD EXECUTION PLAN

CP Rail & Cargill

Rev. 1

Owner: TransCanada
Prime Contractor: Ledcor Pipeline Limited
HDD Contractor: Dwayne Unger Construction Limited
TransCanada
Keystone Pipeline Project – Execution Phase
HDD Execution Plan

CP Rail & Cargill

TABLE OF CONTENTS

1 INTRODUCTION .......................................................................................................1
1.1 Horizontal Directional Drill Procedure................................................................1

2 EXECUTION PLAN...................................................................................................2
2.1 Notifications and Permits ...................................................................................2
2.2 Identification of Buffer Zones .............................................................................2
2.3 Pre-Construction Survey....................................................................................2
2.4 Equipment on Site .............................................................................................3
2.5 Project Entry/Exit Points ....................................................................................3
2.6 Surface and Guide Casing.................................................................................4
2.7 Tracking System ................................................................................................4
2.8 Drill Fluid Pressure Report.................................................................................4
2.9 Pilot Hole ...........................................................................................................6
2.10 Reaming and Hole Opening ..............................................................................6
2.11 Drill Continuance Plan .......................................................................................6
2.12 Drill Fluid Program .............................................................................................8
2.13 Schedule............................................................................................................8
2.14 Buoyancy Control ..............................................................................................8
2.15 Pullback Procedure............................................................................................8
2.16 Cleanup & Restoration.......................................................................................9
2.17 Water Requirements..........................................................................................9

3 ENVIRONMENTAL MANAGEMENT ......................................................................10

3.1 Planning...........................................................................................................10
3.2 Monitoring ........................................................................................................11
3.3 Response.........................................................................................................11
3.4 Directional Drill Mud Release Contingency Plan .............................................12

CP Rail & Cargill HDD Execution Plan

1 INTRODUCTION
1.1 Horizontal Directional Drill Procedure

CP Rail & Cargill 135m

The trenchless method selected for the crossing(s) is a horizontal directional drill
(HDD) crossing technique. The following is an overview of the steps that will be
involved in the execution of the HDD crossing. It will also outline some of the
mitigative measures that will be taken to ensure the effective installation of the
proposed crossing. These measures will be in conjunction with the measures
outlined in the Environmental Protection Plan (EPP) for this project.

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2 EXECUTION PLAN
2.1 Notifications and Permits
Prior to access or construction activities associated with the crossings, all
crossing approvals, permits, and/or notifications will be received or issued
respectively. All conditions specified in approvals or permits will be discussed,
understood, and adhered to by company personnel and all contractors. Any
required notifications required in the permits/approvals or notifications will be
provided within the timing specified. Notifications will be completed as specified,
documented, and maintained in the construction field office.

2.2 Identification of Buffer Zones

All buffer zones or restricted areas will be identified and flagged prior to
mobilization and site preparation. In addition, any restricted areas identified by
permits/approvals will be flagged off. Access to these restricted areas will be
prohibited unless authorized by the appropriate regulatory authority in the case of
permits/approvals or by the authorized Keystone representative.

2.3 Pre-Construction Survey

A pre- construction survey will be completed to confirm the entry and exit points
for the pilot bore as shown on the construction drawings and as staked in the
field. A survey examination of entry and exit points will be done prior to casing
installation or rig-up to verify distances, field stations and elevations along the
proposed centerline. These points will be plotted for the monitoring and
recording of the three dimensional coordinates generated by the magnetic
guidance tracking software. This exercise ensures the pre-alignment and radius
restrictions are maintainable during the execution of the bore. Following receipt
of the survey results a comparison to the engineered designed profile will be
verified and presented to the Clients Representative or concerned parties for
review and approval prior to drilling operations starting.

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2.4 Equipment on Site
All equipment used on site shall be cleaned and free of oils, fuel, grease, coolant
and other hydrocarbons or otherwise toxic substances, or any vegetation, soil or
other material prior to mobilization, as per the Environmental Protection Plan
(EPP). Oil changes, refuelling, and lubrication of mobile construction equipment
will only be undertaken on the Right-of-way (ROW) or temporary work space
(TWS) Fuel containers will be dual walled tanks or alternatively will be contained
within containment berms constructed to a capacity of 125% of the fuel stored, as
per EPP Appendix E, Specific Measures, #12. Contingency plans will be in place
in the event of fuel or hazardous waste spills.

Equipment Summary
(Note: Equipment changes or substitutions may occur)

Drill:
- 440 Drill rig
- 440,000 lbs of thrust/pull
- 60,000 ft lbs of rotary torque.
- Anchor System: Piling and Deadman system

Or

- 220 Drill rig

- 220,000 lbs of thrust/pull
- 30,000 ft lbs of rotary torque.
- Anchor System: Piling and Deadman system

Cleaning System:
-246 Twin Shakers
-2-10 Cones 146 Shaker
-16-4 Cleaner 146 Shaker

Auxiliary equipment:
-500 Emsco pump capable of 1.9 cubes per minute
-monel
-hevi-wate

Drill Size and Type:

-Jet assembly. Size to be determined in field.
-5 inch drill stem

Rig layout and site setup may vary as per the provided work space.

2.5 Project Entry/Exit Points

During site preparations the size, slope grade, berm walls and ingress and
egress will be required for both entry and exit points. The HDD equipment
preferred footprint required on entry is 45m wide x 60m in length, with a level
grade to ensure safe and efficient drilling operation. Rig matting will be placed
on entry to ensure a safe and effective working environment. All mitigative

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 measures indicated in the EPP will be adhered to in the staging of HDD
equipment (Minimum disturbance).

Sumps or buried tanks will be required on entry and exit points to contain drilling
fluids no larger than 12m in length x 3.5m wide & 1.5m in depth. Support
equipment will be required to assist in all exit side operations.

A staging area will be used to string, weld, coat, and pre-test the pipeline before
pull through. The primary staging area will be located near the exit side of the
crossing and will be contained within the existing right-of-way limits or temporary
work space.

2.6 Surface and Guide Casing

An experienced contractor will be used to install entry or exit casings in the event
it is required for the crossing. Casing will be installed according to the geo-
technical information, profile design and/or casing refusal occurs. Casing will be
cleaned by the casing contractor or the HDD rig. Unger personnel will be on site
to ensure the accuracy of the casing installation and a casing report will be
submitted to Client’s Representatives for approval. If required 48” x 0.750w
casing may be installed on entry no greater than 16-degrees to ensure a safe
and effective work area. A 16” centralizer casing will be inserted through the 48”
conductor casing and a seal test performed on both.

2.7 Tracking System

A magnetic guidance system, Tru-tracker or Paratrack, will be used to track and
to monitor the drill path during the HDD pilot bore (determination of tracking
system will be based on availability at time of drill execution and as specified in
the specifications of the contract document). This system is important to insuring
the proper installation of the HDD design. This system allows the drilling
assembly to control the path the drill takes and calculate the horizontal and
vertical coordinates relative to the initial entry point on surface. A coil grid will be
laid out accordingly on exit/entry points using surveyed stations to ensure the
accuracy of the drill path. This system will be used to generate an as built profile
of the drilled bore.

In the event of a deviation of the drill path the Clients Representatives will be
informed, if required the drilling assembly will be pulled back to an appropriate
location in the bore path and a steering correction initiated. An annular pressure
tool will be run in conjunction with the downhole assembly directly behind the
mudmotor to ensure the proper monitoring of annular and downhole pressures.
An annular pressure graph will be in the control room for reference. For the
shorter bores a Digi-trak walk over system will be used.

2.8 Drill Fluid Pressure Report

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 Unger HDD will calculate the maximum permissible annular pressure, and create
a report that graphically depicts the maximum permissible annular pressure
along the length of the drilled hole. One (1) copy of the report will be maintained
by the Rig Manager and will be used to govern operating procedures. One copy
will be submitted to the Client Representative. The maximum permissible
annular pressure will not be exceeded without authorization from the Client
Representative and the Rig Manager.

Pressures reaching the upper limit of 25% over expected or falling 25% below
expected will trigger a response to take action to prevent fluid loss. The response
will be as follows:

High annulus pressure

Sudden increase
1. Trip pipe back until pressure drops; a full trip back to entry may be
required.
2. Reduce or stop pumping if pressure does not drop
3. Check mud parameters
4. Check for volume loss
5. With pressure stabilized slowly increase pump speed up to a maximum
flow capacity

Gradual increase over expected

1. Check fluid parameters and modify if required
2. Compare actual drill path to planned
3. If pressure reaches the upper limit, trip back to lower pressures and
condition the hole

Low annulus pressure

Sudden decrease below expected
1. Stop pumping
2. Check returning fluid and volume loss
3. Check for correct tool operation (if point 2 is okay)
4. Prepare a lost circulation mixture and pump down.
5. Monitor for fluid loss
6. Trip back to entry to clean hole and allow plugging agents to work
7. recheck for correct pressure tool operation
8. Trip back while monitoring for fluid loss

Gradual decrease below expected

1. Check drilling fluid parameters
2. Compare drill path to planned
3. Check for reduced flow and fluid loss
4. Mix up lost circulation material and pump down
5. Continue to drill monitoring for reduced flow and volume
6. If losses exist additional plugging agents may be required
7. Monitor for fluid to surface

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2.9 Pilot Hole
To initiate the pilot bore, the HDD is set-up in alignment with the inclination &
azimuth according to the engineered design. The steering tool and drill tooling is
then assembled (DHA.). The steering tool is then calibrated and a 4 point roll
check completed. Measurements will be taken of the DHA and from the bit to the
steering probe. The distance from the HDD vices to the entry point will be
recorded and each additional drill pipe measured and recorded in successive
order. A non magnetic collar will be placed behind the downhole assembly in
order to create a non-magnetic buffer between the steering tool and possible
magnetized drill string. The path of the pilot bore will be recorded by taking
periodic readings of the inclination and azimuth using the tracking system to
calculate the vertical and horizontal coordinates relative to the initial entry point.
These reading will be taken in intervals not to exceed 10 meters to ensure
deviation and design parameters are maintained. Drilling fluid will be pumped
through the downhole assembly no greater than 1.9 cubic meters/min. and no
greater than 1200 psi. Drilling fluid returns will accumulate in a contained sump
or tank and be pumped using a 6’ Gorman Rupp or Godwin centrifugal pump to
the mud reclaimer for reuse. Solids control will consist of 2 rough cut 146 Tri-flo
shakers. A shale tank will be used to contain drilling cuttings.

A jetting assembly along with an annular pressure tool will be used on this pilot
bore. Real time pressures will be recorded by the drilling instrumentation system,
where an annular pressure system is not available Unger HDD will
mathematically model the drilling fluid in use and calculate the expected
standpipe pressure and a maximum permissible standpipe pressure. This data
will be available to the Client Representative at all times and will be printed every
24 hours.

2.10 Reaming and Hole Opening

Once the pilot bore is exited according to the specified tolerances, the bore is
then enlarged using hole openers in a series of sizings. The anticipated phases
for the bore are as follow but not limited to;
Casing Installation
12” pilot
18”-24” fly cutter
24”-36” fly cutter
36”-42” fly cutter and packer
While reaming swabbing, cleaning passes will be performed as required to
ensure that the bore is free of obstructions for the next required opening. At least
one reaming pass will be performed after the final opening to ensure a clean bore
for the pull section.

2.11 Drill Continuance Plan

In the event of a frac-out TransCanada, Ledcor Pipelines Limited and the HDD
contractor in association with any appropriate regulatory agencies will determine

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 an appropriate drill continuance plan. The drill continuance plan may (but is not
limited to) include the following:

1. Fracture Plugging (Bridging) Agents

In certain types of formations or conditions, fracture plugging agents (non-
toxic) have been utilized with limited success. Should these agents be
required a selection of the appropriate agent with MSDS sheets will be
submitted to TransCanada for approval. These are pumped down the drill
hole left undisturbed for a predetermined length of time where upon drilling is
restarted. If positive circulation is restored, drilling is continued using the
same principles and contingency plans; if not drilling is halted.

2. Down Hole Cementing

If the fracture zone is determined to be too large for the use of plugging
agents, the drill string maybe inserted to a predetermined depth to allow a
quick setting cement or thermal resin (non-toxic) to be pumped down-hole in
sufficient quantities to seal off the problem zone. If no further fracturing
occurs, drilling is continued using the same principles and contingency plans;
if not, drilling is halted.

While down hole cementing is rarely used, should it be required a plan with
MSDS sheets will be submitted to TransCanada for approval.

3. Contain and Control

If the inadvertent release is on land, determined not to be causing an adverse
effect, and the surface migration of the drilling mud can be adequately
contained and controlled, then drilling can continue with the following
conditions:
o There are no impacts to the environment or other adverse effects (i.e. no
potential to contaminate surface or ground water, third party property
damage or safety risks to the landowner, public or animals.)
o The surface migration of the drilling mud is adequately contained (bermed
with subsoil or a catch pit excavated);
o The contained free drilling mud is adequately controlled (any free drilling
mud migrating to the surface is immediately and continually removed for
the duration of the remaining drilling phase.
o The site is monitored at appropriate periods during the drilling cycle and
the drilling contractor reduces pump/hole pressure accordingly in order to
maintain control of the amount of mud being contained
o The plan is discussed with appropriate regulatory agencies and their
approval is obtained; and
o The affected site is remediated and reclaimed to meet approved criteria.

In the event that none of the above procedures are successful or considered
feasible, the hole will be abandoned, and a re-drill will be considered at a
second location if it can be determined that more favorable geotechnical
conditions exist, using the same principles and contingency plans.

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2.12 Drill Fluid Program

As per the EPP the drill will be initiated with a water only system. If it is
determined that the drill can not be completed with a water only fluid system,
bentonite and other mud additives may be utilized as approved by
TransCanada’s representative(s).

2.13 Schedule
Mobilization 1 - 12 hr shift(s)
Rig-up 2 - 12 hr shift(s)
Pilot bore 2 - 12 hr shift(s)
20”-24” ream, 2 - 12 hr shift(s)
20”-24” swabbing 1 - 12 hr shift(s)
30”-36” ream 2 - 12 hr shift(s)
30”-36” swabbing 1 - 12 hr shift(s)
42” ream 2 - 12 hr shift(s)
42” swabbing 1 - 12 hr shift(s)
Down time and contingency 1 - 12 hr shift(s)
Pre swab 1 - 12 hr shift(s)
Pipe Pull 1 - 12 hr shift(s)
Rigout and Demobilization 1 - 12 hr shift(s)

The CP Rail & Cargill crossing should take approximately 18 - 12 shift(s). As

required and subject to TransCanada approval execution of the drill can proceed
as either a 12 hr or 24 hr daily work schedule.

2.14 Buoyancy Control

It is anticipated that minimum rig size requirement without a buoyancy control is
will not exceed 220,000 lbs of push/pull thrust. As a 440,000 or 220,000 lbs rig
will be used no buoyancy control plan is required. TransCanada will advise the
contractor if buoyancy control measures are to be implemented.

2.15 Pullback Procedure

After the swabbing ream is completed, the pull section is then attached to the
hole opener using a swivel minimizing torsion forces transmitted to the pull
section. Product pipe handling equipment will be required to assist and align the
pull section in such a manner as to reduce axial tensional loads imposed on the
pull section. It is recommended not to exceed a 14 degree exit angle to prevent
excessive tensional forces. Pullback forces will be recorded and available to the
Clients Representative during and after the pullback is complete. If required
buoyancy control maybe used during pullback operations, as the pull section is
advanced to the lowest elevation of the bore, water will be inserted into the
pipeline to achieve neutral buoyancy, reducing the tensional force required to

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 advance the pull section. Water used for buoyancy control will be disposed of by
the prime contractor/Client.

2.16 Cleanup & Restoration

Following the completion of the HDD, the pipeline right-of-way and associated
temporary work space will be cleaned up and restored to original conditions. All
measures indicated in the EPP will be followed during clean-up and restoration
activities.

Drilling fluids and cuttings/solids will be disposed of in accordance to Alberta

Energy Resource Conservation Board (formerly Energy Utility Board) Directive
50 “Drilling Waste Management”. A landspray while drilling, landspread, and/or
mix-bury-cover program will be implemented to dispose of the drilling fluids and
cuttings/solids. Both fluids and solids may be stored on site in sumps, tanks, or
other structures prior to final disposal. Offsite disposal locations, if required, will
be determined in field and approved by a TransCanada representative.

Volumes of both fluids and cuttings/solids for disposal can be highly variable but
are estimated at 162 m3 for fluids and 243 m3 for cuttings/solids.

A report detailing the drilling mud disposal outcomes (e.i. location, procedures,
quantities, analytical reports, etc.) will be provided to Keystone and to provincial
regulators where required.

2.17 Water Requirements

Estimated water usage for the drill project is 170 m3. TransCanada is to provide
an approved water source.

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3 ENVIRONMENTAL MANAGEMENT

3.1 Planning
The HDD management plan for CP Rail & Cargill has been developed to
minimize environmental impact. The HDD crossing plan meets the requirements
of the EPP. In addition to the EPP, the following mitigation measures will be
implemented during the HDD crossing of CP Rail & Cargill.

General
The HDD contractor will comply with the plan prepared for the works, except
where measures must be taken to deal with an emergency.

Deleterious Materials

The Prime Contractor will:

Provide the HDD contractor with a level work pad, and will construct a dirt berm
around the work pad no less than 0.3 metres in height;

Be responsible for managing any dewatering procedures;

Limit use of hazardous materials.

MSDS for fuel, lubricants, and mud products will be onsite.

Equipment:
All HDD equipment arriving on location is free from engine oil, hydraulic oil, fuel,
and coolant leaks;

All HDD equipment arriving on location is free from dirt, mud, vegetative debris,
and other substances that may impact land productivity;

Restrict all equipment to cleared Right-of Way and work space;

All portable equipment using fuel, hydrocarbon lubricants, coolants such as

electrical generators and pumps used off of the bermed entry or exit work pad
will be positioned inside of a sandbag berm (or equivalent) lined with leak free
polyethylene or other containment structure that serves to prevent deleterious
substances such as fuel from contaminating soils or vegetation;

All fuels, lubricants, coolant, and other substances are contained, controlled,
and handled according to either Alberta or Manitoba Occupational Health
Safety regulations, the Keystone, and the HDD contractors safety policy and
procedures

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 In the event of a spill or accidental release, the appropriate response will
proceed as per EPP Appendix G, Spill Contingency Plan.

Waste Management
The composition of the drilling fluid will be limited to fresh water. If required for
successful drill completion and approved by TransCanada high yield
bentonite, and/or other additives conforming to or exceeding American
Petroleum Institute and Petroleum Services Association of Canada
specifications may be used.

An MSDS sheet is maintained on the work location for all drilling fluid additives.

Any change to the HDD plan requires prior approval from Keystone.

3.2 Monitoring
The HDD contractor will monitor the drill path and ROW for frac-outs and drilling
fluid releases.

The HDD contractor will monitor, by visual and electronic means:

o The return flow of drilling fluid from the borehole. A reduction in return
flow shall be taken as indicating a possible seepage of drilling fluid.
o The annular and / or standpipe pressure. An unplanned reduction in
pressure shall be taken as indicating a possible seepage of drilling fluid.
o The tank and pit volumes.
Any unplanned losses or gains will be reported to the Keystone
Representative.

Monitoring personnel will have communications with drilling personnel at all

times during daylight monitoring.

Night-time monitoring will not occur where it is deemed unsafe and hazards
cannot be addressed by proper controls.

All appropriate safety precautions and plans will be undertaken to meet

TransCanada and Regulatory requirements.

Monitors will increase monitoring if monitoring of drilling mud returns indicate

that a release may have occurred.

3.3 Response

The Rig Manager is the on-site authority for the HDD contractor. The Rig
Manager has the authority to direct the rig crew, and the materials and
equipment towards the protection of the environment.

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 In the event a frac-out is observed, drilling will be stopped and contingency
measures implemented.

3.4 Directional Drill Mud Release Contingency Plan

Objectives

The contingency plan outlined below has been developed and will be employed
to meet the following objectives:

To ensure Contractor has specific measures in place in the event of a

inadvertent mud release and that potential impacts are minimized; and

To ensure corrective action processes are in place to properly manage

inadvertent releases of drilling mud.

The Rig Manager is responsible for implementing and maintaining all mitigation
measures unless otherwise specified.

Specific Measures

Cleanup Plan

1. Develop a cleanup plan, before drilling. The plan will be prepared with the
drill contractor in consultation with Keystone inspection staff. Acquire the
appropriate approvals to access the release area if off right-of-way and for
mud pump-off.

2. Ensure that supervisory personnel are aware of the contingency plan (EPP
Appendix F, Directional Drill Mud Release Contingency Plan) and cleanup
plan before commencement of drilling activity.

Surface Casing

3. Install surface casing at the entry point to a depth that extends beyond the
coarsest material, if warranted.

4. Install surface casing at the exit point, after completion of the pilot hole if
coarse textured near-surface deposits could interfere with drilling mud
circulation.

Mud Composition

5. The composition of drilling fluid will be limited to fresh water. If required for
successful drill completion and approved by TransCanada high yield
bentonite and other additives conforming to or exceeding American
Petroleum Institute and Petroleum Services Association of Canada
specifications may be utilized.

Drilling Sumps

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 6. Construct subsoil berm(s) or sump(s) down slope from the entry point and
proposed exit point with a capacity adequate to capture anticipated volumes
of drilling mud that could be release during pullback and other drilling
operations.

Contingency Plan Equipment and Supplies

7. Certain equipment will be required onsite in sufficient quantities during drilling

operations to contain any inadvertent drilling mud releases. This equipment
and supplies may include:
• sandbags;
• filter cloth (e.g., silt fence);
• t-bar posts;
• straw bales;
• shovels;
• 6 mil polyethylene or equivalent; and
• trash pumps c/w sufficient lengths of leak free hose and suction heads.

8. Maintain vacuum trucks onsite during pullback operations as necessary. In

addition vacuum trucks can be mobilized during the pilot and reaming phases
if required.

9. All of the HDD equipment on site is available to effect an emergency

containment of seepage of drilling fluid, and will be directed by the Rig
Manager

Manpower

10. All of the HDD contractor manpower are available to effect an emergency
containment of seepage of drilling fluid, and will be directed by the Rig
Manager.

Monitoring

11. Supervisory personnel will be onsite at all times during drilling, reaming and
pullback operations to ensure that contingency plan measures will be
implemented immediately and effectively. Keystone will also assign
inspection personnel to the site during all phases of the drill.

12. Monitor and record the amount of fluid return to the mud tank/pit and the
amount of makeup drilling fluid required in the mixing tanks during drilling of
the pilot hole and reaming.

13. Monitor the drill path and surrounding area (i.e., within 200m minimum) for
signs of drilling mud release. The size of the area to be monitored will be
determined by evaluating geo-technical conditions (i.e., amount of fracturing,
type and depth of substrate) and drilling conditions (i.e., depth of drill path,
distance between entry and exit points). Monitoring will be on a continual
basis during drilling operations and will continue for at least 12 hours after

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 shutdown. Ensure that contact is maintained at all times between monitoring
and drilling personnel.

Response

14. Where seepage of drilling fluid migrates to the surface the Rig Manager will
initiate the emergency response plan.

15. The observation of a reduction in flow of drilling fluid will constitute a

detection of a possible occurrence of seepage, and thus, if a reduction in the
return flow of drilling fluid should occur, the Rig Manager will;
• Stop the advancement of the drilling assembly, pull the drive carriage to
the top of the derrick, and shut off the drilling fluid pumps
• Conduct a survey of the ground surface for evidence of seepage of
drilling fluid to surface.
• Notify the Keystone Representative.
• Assemble measurement data such as annular and/or standpipe pressure,
forward thrust pressure, and observations such as the behavior of the
return flow. Evaluate the measurement data and observations with the
Keystone Representative.
• Assist the Keystone Representative in developing a Drill Continuance
Plan that satisfies the requirements of the EPP when so advised,
• Wait on orders from the Keystone Representative

Seepage

16. If seepage of drilling fluid to surface does occur, the Rig Manager will:
• Stop all drilling operations.
• Contain the seepage by erecting a sandbag and polyethylene berm (or
other fit- for-purpose material), or by digging a pit, or a combination of
both.
• Notify the Keystone Representative.
• Develop and implement a recovery and clean up plan with the Keystone
Representative.
• Assemble measurement data such as annular and/or standpipe pressure,
forward thrust pressure, and observations such as the behavior of the
return flow.
• Evaluate the measurement data and observations with the Keystone
Representative.
• Assist the Keystone Representative in developing a Continuance Plan
that satisfies the purposes of the EPP.
• Document the incident according to company procedures.

Pilot Hole Deviation

17. If the pilot bore encounters conditions that interfere with steering accuracy,
then the Rig Manager and Keystone will need to take the appropriate action
to complete the crossing. These actions could include:
• Accepting the new drill path; and/or
• Adjusting the depth of the borehole path so the drill can avoid the
problematic stratum; or

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 • Pulling out, moving over and drilling a new pilot hole; or
• Abandoning the pilot and advising DFO of HDD failure. Requesting
approval of the use of the contingency crossing method.

Loss of Circulation

18. If loss of circulation is encountered during the HDD, then the Rig Manager
and Keystone will need to assess the extent of fluid loss, determine its likely
cause and take the best remedial action. These actions may include:
• Determining the fluid loss acceptable and continuing to drill/ream/pull; or
• Stopping the operation, re-establishing circulation and restarting the
operation; or
• Abandoning the hole, moving over, and boring a new crossing path; or
• Abandoning the hole and requesting approval of the use of the
contingency crossing method.

Given that there are many factors to consider in determining if the HDD fails, a
full evaluation of all relevant data will be made and all reasonable options will be
considered prior to seeking approval to use the contingency plan.

Waste Management

The Contractor and the Rig Manager will put in place the following measures in
place to maintain the cleanliness of the work site.
• Store deleterious substances used in the operation and maintenance of
equipment in approved containers, and store containers in a location and
in a manner that protects them from being punctured, crushed and leaked
onto the sol or vegetation.
• Provide segregated waste disposal containers for all general waste, and
dispose of such waste.
• Provide sanitary facilities for crew.
• Backfill and stabilize any pits excavated for anchoring or containment.
• Dispose of all waste drilling fluid and drilled solids according to and in
conformance with AEUB Directive 50 and other regulatory requirements.
• Follow the waste management procedures as outlined in Appendix D, of
the Environmental Protection Plan

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