Mid-Atlantic Express Pipeline HYDROTESTING AND PRE-COMMISSIONING PLAN

AES MID-ATLANTIC EXPRESS PIPELINE PIPELINE HYDROTESTING AND PRE-COMMISSIONING PLAN January 2007

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Mid-Atlantic Express Pipeline HYDROTESTING AND PRE-COMMISSIONING PLAN

TABLE OF CONTENTS 1. PROJECT DESCRIPTION..................................................................................................2 2. DESIGN CONSIDERATIONS.............................................................................................2 3. PERMITTING........................................................................................................................4 3.1 Intake......................................................................................................................................4 3.2 Discharge................................................................................................................................5 4. PRE-COMMISSIONING......................................................................................................6 4.1 General ..................................................................................................................................6 4.2 Water Treatment.....................................................................................................................6 5. FLOODING, CLEANING AND GAUGING .....................................................................6 5.1 General ..................................................................................................................................6 5.2 Pipeline Flooding.......................................................................................7 5.3 Discharge..... .................................................................................................7 5.4 Final Cleaning Records... ....................................................................................................7 6. HYDROTESTING ................................................................................................................8 6.1 General ..................................................................................................................................8 6.2 Pre-Hydrotest of HDD Segments...........................................................................................8 6.3 Final Hydrotest.......................................................................................................................9 6.4 Hydrotest Failure....................................................................................................................9 7. DEWATERING....................................................................................................................10 7.1 General .................................................................................................................................10 7.2 Dewatering Runs...................................................................................................................10 7.3 Water Disposal......................................................................................................................10 7.4 Dewatering Records..............................................................................................................10 8. DRYING.................................................................................................................................11 9. INERTING AND PURGING................................................................................................11 10. PLANT AND EQUIPMENT...............................................................................................11 10.1 Water Flooding Spread ........................................................................................................11 11. ENVIRONMENTAL ASPECTS.........................................................................................12 11.1 Intakes...................................................................................................................................12 11.2 Discharge..............................................................................................................................12 12. REFERENCES......................................................................................................................13 APPENDICES A. Water Volume Calculations B. Material Safety Data Sheet for Water Tracing Dye C. Material Safety Data Sheet for Typical Hydrotest Water Additives 2 January 2007

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D. Hydrotest Discharge Drawings

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1. PROJECT DESCRIPTION AES Sparrows Point LNG, LLC (Sparrows Point LNG) proposes to construct, own, and operate a new liquefied natural gas (LNG) import, storage, and regasification terminal (LNG Terminal) at the Sparrows Point Industrial Complex situated on the Sparrows Point peninsula east of the Port of Baltimore in Maryland. LNG will be delivered to the LNG Terminal via LNG marine traffic, offloaded from these ships to shoreside storage tanks, regasified on the LNG Terminal site (Terminal Site), and transported to consumers via pipeline. The LNG Terminal will have a regasification capacity of 1.5 billion standard cubic feet of natural gas per day (bscfd), with potential to expand to 2.25 bscfd. Regasified natural gas will be delivered to markets in the Mid-Atlantic Region and northern portions of the South Atlantic Region, through an approximately 88-mile, 30-inch outside diameter natural gas pipeline (Pipeline) to be constructed and operated by Mid-Atlantic Express, LLC (Mid-Atlantic Express). The Pipeline will extend from the LNG Terminal to interconnections with existing natural gas pipeline systems near Eagle, Pennsylvania. Together, the LNG Terminal and Pipeline projects are referred to as the Sparrows Point Project or Project. Both Sparrows Point LNG and Mid-Atlantic Express (hereinafter collectively referred to as AES) are subsidiaries of The AES Corporation. The Project footprint is located in the counties of Baltimore, Harford and Cecil in Maryland, and in the counties of Lancaster and Chester in Pennsylvania. The Terminal Site, which is located entirely within Baltimore County, is a parcel located within a former shipyard. The route proposed for the Pipeline (Pipeline Route), which crosses all of the listed counties, includes industrial, commercial, agricultural, and residential lands. Together, the Terminal Site and the Pipeline Route comprise the Project Area. As described in Section 1.10 of Resource Report 1, General Project Description, The AES Corporation is considering the possibility of building a combined cycle cogeneration power plant (Power Plant) on the Terminal Site. The Power Plant would be configured with one F-Class combustion gas turbine, one steam turbine, and associated auxiliaries. It would operate only on natural gas and would produce approximately 300 megawatts (MW) of clean electric power within an area of high energy demand. The Power Plant would be connected to the local utility electric system via an overhead transmission line. This document describes the plan for testing and pre-commissioning of the MidAtlantic Express pipeline. For the purposes of this document, testing and precommissioning refers to the final installation activities carried out prior to the introduction of natural gas into the pipeline transportation system. 2. DESIGN CONSIDERATIONS After the new 30 pipeline is constructed, the pipeline must be tested to at least 140% of the maximum allowable operating pressure (MAOP) for a period of 8 hours per ASME B31.8, Table 841.322(f). ASME B31.8 is incorporated by reference in DOT 192. The 8 hour requirement is due to the inability to inspect the pipe for leakage during the test since the pipe will be buried. The established MAOP necessary to meet flow capacity requirements is 2,080 psig. Therefore, the minimum required test pressure is 2,912 psig at the high point of each test section. There is no limit on the maximum 4 January 2007

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test pressure although it typically will be from 95% to 100% of SMYS (Specified Minimum Yield Stress). AES has performed a class study for the pipeline based on an assessment of the geographical areas along the Mid-Atlantic pipeline route. Based on this assessment and the requirements of USDOT, 49 CFR Part 192, Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards the majority of the 88 mile route meets criteria for a Class 3 area with portions of the pipeline route designated as Class 4 areas from MP 1.6 to 9.9 and MP 83.6 to 87.5. The selected pipe specification for the pipeline in a class 3 location is 30 OD, 0.938 wt, API 5L X70 grade. The design pressure for the pipe is 2,189 psig for a Class 3 location. This design pressure exceeds the desired maximum operating pressure of 2,080 psig. The selected pipe specification for the pipeline in a Class 4 location is 30 OD, 1.125 wt, API 5L X70 grade. The design pressure for the pipe is 2,100 psig for a Class 4 location. This design pressure exceeds the desired maximum operating pressure of 2,080 psig. The 88 miles of 30 pipeline from Sparrows Point, Maryland to Eagle, Pennsylvania will be tested in two sections. Test Section #1 will extend from the west bank Susquehanna River to the Northern Terminus of the Pipeline in Eagle, Pennsylvania (MP 43.6 to 87.6). Test Section #2 will extend from the initiation point of the pipeline at the AES Sparrows Point LNG Terminal to the west bank of the Susquehanna River (MP 0 TO 43.6). The two test sections are shown on the figures in Appendix D. The pipeline elevations, test pressures and specified minimum yield stress for each test section are as follows: Test Section #1 From MP 43.6 to MP 87.6 Low Elevation @ MP 43.9, High Elevation @ MP 63.3 Elevation @ MP 87.6 Test Section #2 From MP 0.0 to MP 43.6 Low Elevation @ MP 0.0, Proof test 120 ft. 640 ft. 480 ft. %SMYS Max. test 71.7 4,158 psig 66.5 3,933 psig 68.1 4,041 psig %SMYS 95.0% 89.8% 92.3%

3,137 psig 2,912 psig 3,020 psig

0 ft.

3,167 psig

72.3 4,158 psig 66.5 3,903 psig 69.8 4,046 psig

95.0% 89.2% 92.4%

High Elevation @ MP 30.25 590 ft. 2,912 psig Elevation @ MP 43.6 260 ft.3,055 psig

AES has evaluated selected critical water bodies for crossing using the Horizontal Directional Drilling (HDD) method, consistent with the request by National Marine Fisheries Service (NMFS). As described in Resource Report 2, Water Use and Quality, to avoid potential impacts to wetlands and water-bodies, and potential disruption of local traffic (highway and rail), AES has proposed two (2) HDD sections for the pipeline.
1.

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As shown on the figures included in Appendix D, the locations of these HDD sections are: HDD #1 - MP 9 crosses Back River, approximately 2 miles east of the city of Baltimore, located in Baltimore County, Maryland. HDD #2 MP 43.6 crosses the Susquehanna River, between Darlington, Harford County and Conowingo, Cecil County, Maryland.

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3. PERMITTING Before any segment of proposed Pipeline is placed in-service, it will be hydrostatically tested to ensure it conforms to U.S. Department of Transportation (Part 192) specifications. Water will be required during the pre-commissioning operations of the Mid - Atlantic Express Pipeline for flooding, cleaning, and hydrotesting. Hydrotesting will be required for the following sections and segments of the pipelines: Test Segment #1 from MP 43.6 , Darlington, Harford County, Maryland, to MP 87.6, Uwchland, Chester County, Pennsylvania. Test Segment #2 from MP 0.0, Sparrows Point, Baltimore County, Maryland, to MP 43.6, Darlington, Harford County, Maryland Each of the two HDD sections listed in Section 2. above (HDD#1 and HDD#2) A total of approximately 7,600,000 gallons of water will be required for flooding, cleaning and hydrotesting of the pipeline. Potential impact to sensitive waterbodies (fisheries) has been considered in the preparation of this hydrostatic test plan. AES currently plans to withdraw the hydrostatic test water from the Susquehanna River. Prior to withdrawal of hydrostatic test waters, AES will coordinate surface water withdrawal with the Susquehanna River Basin Commission (SRBC), and will obtain as well as a Permit to Appropriate and Use Waters of the State from the Maryland Department of the Environment (MDE), as further described below in Section 3.1. AES is also evaluating the feasibility of drawing the hydrostatic test water from the Baltimore County POTW or another public water supply. Once the hydrostatic test is completed, AES will need to discharge the hydrostatic test waters. Prior to initiation of the hydrostatic test, AES will apply for coverage under the Maryland General Permit for Discharge of Hydrostatic Test Waters (COMAR 26.08.04.09.K) as further described below in Section 3.2. 3.1 Intake Prior to withdrawing water from State of Maryland waters for use during precommissioning, Mid-Atlantic Express will obtain a Water Appropriation and Use Permit from the MDE Water Management Administration (WMA) in accordance with COMAR 26.17.06. Additionally, AES will coordinate surface water withdrawal with the Susquehanna River Basin. Water used for hydrostatic testing of the Susquehanna River directional crossing will be taken from the Susquehanna River. Hydrostatic test water used for testing the directional crossing at the Back River will be potable water hauled to the test site by transport trucks. Water used for hydrostatic testing the installed pipeline will be taken from the Susquehanna River. Potential impact to sensitive waterbodies (fisheries) has been considered in the preparation of this hydrostatic test plan. The hydrostatic test water intake structures will be designed avoid juvenile and adult fish entrainment and the disturbance of bottom sediments by placing restrictions on bottom draw and requiring a screen at the intake as well as velocity controls consistent with EPA guidance and permits from local agencies.

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Marylands cooling water intake and discharge regulations (COMAR 26.08.03) stem from Sections 316(a) and (b) of the CWA. COMAR 26.08.03.05, and litigative and administrative rulings stipulate that the location, design, construction and capability of cooling water intake structures must reflect the best technology available (BTA) for minimizing adverse environmental impacts, providing that the costs of implementing the BTA are not wholly disproportionate to the expected environmental benefits. Maryland law exempts facilities with withdrawal rates less than 10 million gallons per day (MGD) and less than 20 percent of stream or net flow by the intake. Marylands regulations do not specify a design intake velocity, and typical Maryland facilities generally have a 1 to 2 fps screen face velocity. While AES does not propose to construct a cooling water intake system, these regulations were utilized as the guidance for the conceptual design of the proposed hydrostatic test water intake structure that would be used to provide hydrostatic test water for each pipeline segment. As such the hydrostatic test water intake structure will be designed to minimize entrainment of marine organisms through effective use of a low velocity suction intake system, designed for less than 2 fps with a velocity-cap. Both water intake and discharge are anticipated to be from location(s) within the new pipeline ROW corridor where it crosses the Susquehanna River, with the intake structure extending from the west bank of the river. 3.2 Discharge AES will obtain coverage under the Maryland General Permit for Discharge of Hydrostatic Test Waters (COMAR 26.08.04.09.K), General Permit No 06HT. In accordance with the permit conditions AES will file a Notice of Intent with MDE WMA at least sixty calendar days prior to commencement of activities covered under the general permit. AES will notify the MDE at least 48 hours prior to discharge and will perform sampling and analysis of the discharge in accordance with the Section IV.D of the General Permit, Discharge Limits for Hydrostatic Testing of Pipes, Pipelines and Tanks including the following flow rate, oil & grease, total iron, total residual chlorine, total suspended solids, dissolved oxygen, temperature difference, temperature and pH. The sampling and analytical methods used will conform with the procedures for the analysis of pollutants as identified in 40 CFR Part 136. Dewatering of the pipeline test sections will be conducted as described in Section 7 and in accordance with applicable permit conditions. The following table shows the locations and volumes to be discharged.
Table 3-1 Hydrotest Water Discharge Locations and Volumes Discharge Location Directional Drill Site, Susquehanna River

Purpose of Discharge Susquehanna HDD Hydrotest water Back River HDD Hydrotest water Pipeline Test Section #1

Volume in Gal. 149,000

Discharge MP 43.6

Receiving Water Name Area of considerable vegetation; Tract 655, West Bank Susquehanna River

Local POTW

27,175

Pipeline Test Segment #2 for reuse

7,315,000

Test water will be hauled offsite by transport truck To Test Section #2

Test water will be pumped into Test Section

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Upland area in the vicinity of the Susquehanna River

MP 43.6 MP 87.6 Hydrotest water Pipeline Test Section #2 MP 0 MP 43.6 Hydrotest water

#2; No discharge to waterbody. 7,400,000 43.6 Area of considerable vegetation; Tract 655, West Bank Susquehanna River

Note: Exact discharge locations may be optimized based on field conditions and contractor construction methods.

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4. PRE-COMMISSIONING 4.1 General The pre-commissioning activities for the Project will be carried out as one activity. The main pipeline section will include the entire Mid-Atlantic Pipeline from Sparrows Point, Maryland (MP 0.0) to its terminus in Eagle, Pennsylvania (MP 87.6). The pre-commissioning activities for both proposed hydrotest sections include the following:

Filling, Cleaning and Gauging Hydrotesting Dewatering Drying Purging Inerting

4.2 Water Treatment In the past, the generally accepted industry practice was to treat all water entering a pipeline to prevent corrosion. Due to environmental concerns, the current accepted industry practice is to avoid the use of chemical additives, except under circumstances where the test water will remain in the pipeline for a period exceeding one month. This practice is based on the fact that once initial corrosion occurs, the corrosion creates a very thin layer of rust, and oxygen-induced corrosion will gradually be diminished. The remaining risk to the pipeline will be predominantly due to the presence of microbiological organisms (e.g. sulfate reducing bacteria (SRB) and acid reducing bacteria (ARB)). The Mid Atlantic Express pipeline will be internally coated, which will protect the pipeline from corrosion and the only areas potentially susceptible to corrosion (i.e. uncoated sections) are one foot either side of the field joints. Due to this limited potential for corrosion and the short residence time of the hydrotest water in the pipeline (i.e. less than one month) the use of corrosion inhibitors will not be necessary. 5. FLOODING, CLEANING AND GAUGING 5.1 General Pipe Test Section 1 and Section 2, respectively, will be partially flooded prior to the introduction of scrapers (pigs) in order to avoid uncontrolled pig acceleration due to gravity and the force of the static head of the water behind the pig. After flooding, cleaning will be carried out to ensure that all construction debris, dust, dirt, mill scale and rust are removed from the pipeline. Construction debris dirt, mill scale, and rust will be collected by the contractor in the pig traps at the end of each line segment, loaded in containers and hauled offsite to approved disposal facilities. High velocity water flushing may be used (3 6 ft/sec) to displace mill 10 January 2007

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scale, loosely adhering sand, and debris from the pipeline. A train of pigs specifically designed for cleaning will be propelled along the pipeline as part of the flooding and cleaning operation. Since the pipeline is internally coated, polyurethane scraper pigs, instead of brush pigs, will be used. The pig train will also include a pig fitted with a gauging plate. A gauging pig will be sized to 95% of the nominal internal diameter of the pipeline. This is a specially machined disc used to verify the internal diameter of the pipeline and to ensure that there are no buckles, dents, or excessive ovality. 5.2 Pipeline Flooding Once installed, Test Section 1 will be filled using water pumped from the Susquehanna River. No additives will be used. Listed below are proposed sources of water: A total of approximately 7,315,000 gallons of water will be required for filling and hydrotesting of Test Section #1. Test Section #1 includes a second hydrotest of the HDD of the Susquehanna River. Water will be drawn from the Susquehanna River, the designated source, the intake pipe will be installed with screens and filters and the intake velocity will be restricted to less than 2 ft/sec. In this way, the potential for entrainment or entrapment of aquatic organisms will be minimized. Following a successful hydrotest of Section #1, the 7,315,000 in Test Section #1 will be pushed using pigs and compressed air into Test Section #2. An additional 85,000 gallons will then be pumped from the Susquehanna River as needed to fill Test Section #2. Test Section #2 includes a second hydrotest of the Back River HDD. 5.3 Discharge Any water used to flood, clean and hydrotest the pipeline will be discharged as outlined in Section 7 below. During the cleaning operation, the fill water will be channeled into a holding pool or temporary holding tank, filtered, tested and then discharged in accordance with applicable permit limits. Water treatment will be limited primarily to the removal of debris and contaminants unless circumstances dictate otherwise, since no chemicals will be used during the operation. See section 4.2 for water treatment. If it is determined, after water analysis has been completed, that the hydrotest water can be discharged in uplands without pretreatment, the test water will be released to the ground at a controlled rate utilizing preventative measures to avoid erosion that may include discharge via a diffuser, discharge into riprap, discharge into a splash barrier and/or control of flow rates to avoid erosion of soil in accordance with applicable permit conditions. See Figure 25, Typical Pipe Test Energy Dissipater in Appendix D of this document.

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Any solid residue recovered during cleaning, will be collected and disposed off at a disposal site licensed for the particular type of waste. 5.4 Final Cleaning Records In the final cleaning records, the following data will be measured and recorded: Total volume, pressure and flowrate of cleaning medium for each cleaning step. Quantities and composition of materials recovered at the end of the pipeline. Water disposal information. Data recording records required by applicable permits.

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6. HYDROTESTING 6.1 General After the pipeline has been cleaned of debris and voided of air, hydrotesting of the pipeline can commence. Hydrotesting involves pressurizing the pipeline to a predetermined pressure level and, after stabilization, maintaining the pressure at that level for a set time period. The Mid Atlantic Express pipeline will be tested in accordance with current industry standards, i.e., U.S. Department of Transportation (DOT ) Transportation of Natural and other Gas by Pipeline: Minimum Federal Safety Standards, Title 49 CFR Part 192, and ASME B31.8, Gas Transmission and Distribution Piping Systems. The pipeline and the use of the HDD segments will require a minimum hold time of 8 hours. Individual HDD sections will be tested prior to installation above grade for 4 hours and then tested again once the pipeline has been assembled. Pipeline integrity will be demonstrated by the absence of any pressure loss, other than that which can be attributed to temperature fluctuation. 6.2 Pre-Hydrotest of HDD Segments Each of the HDD pipeline segments will be individually hydrotested to confirm the integrity of each segment before it is pulled through the reamed bore. After installation and tie-in, the HDD segments will be re-tested during hydrotesting of the assembled sections of the pipelines. The HDD segments are short in length relative to the length of the overall pipelines. Consequently, close monitoring and control during segment construction will ensure internal cleanliness, minimizing construction debris. Therefore, there should be little concern regarding contamination of the water to be discharged following the hydrotest. Nonetheless, this test water will be sampled and tested prior to discharge. If the water meets applicable permit requirements and can be discharged without pretreatment, the test water will be released on to the ground and monitored closely to avoid erosion of soil. If treatment is required prior to discharge, the test water will be treated, re-tested and then discharged. The neutralization of the hydrotest water will be performed by adding a neutralizing agent such as hydrogen peroxide. The continuous analysis of the hydrogen peroxide dosage rate and its effect on the neutralization process will dictate the hold period prior to discharge. Solid residuals will be collected and disposed of at a licensed disposal site. The proposed discharge locations for all hydrotest operations are presented above in Table 3-1 and shown on the attached drawings in, Appendix D. 6.2.1 HDD Segments Approximately 27,175 gallons of potable water from a municipal source will be used to flood and hydrotest the Back River HDD segment. The potable water used for the hydrotest will be obtained from a local municipal source trucked 13 January 2007

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in to the construction area. The water will be filtered prior to filling the pipeline segment. After testing, the Back River HDD segment will be dewatered following the hydrotest, subject to installation and tie-in requirements. Prior to discharge, the water will be sampled and tested for contaminants to prevent environmental pollution. Hydrostatic test water fro the Back River HDD test segment will be discharged to trucks and transported to a local POTW where it will be discharged in compliance with the applicable permit requirements. Discharge locations are shown in the Table 3-1, Hydrotest Water Discharge Locations and Volumes Approximately 149,000 gallons of water will be used to flood and hydrotest the Susquehanna River HDD Segment. The water will be obtained from the Susquehanna River in accordance with local permit conditions. The water will be filtered prior to filling the pipeline segment. After testing the Susquehanna River HDD Segment the pipe section will be dewatered, subject to installation and tie-in requirements. Prior to discharge, the water will be sampled and tested for contaminants to prevent environmental pollution. Discharge locations are shown in Table 3-1, Hydrotest Water Discharge Locations and Volumes 6.2.2 Pipeline Approximately 7,400,000 gallons of fresh water will be used to flood and hydrotest the pipeline. The water will be filtered prior to filling the pipeline segment. The ends of the pipeline segments will have test heads installed on each end. These heads will be fitted with valve mechanisms and hoses that will allow the pipeline to be flooded. One of the test heads will have a preinstalled pig to expel any air trapped in the segment prior to the hydrotest. The same pig can be pushed back with compressed air for dewatering, if required. The test section and the terminal ends of the pipe section will be set up with warning signs, bunting and barricades to restrict unauthorized access during hydrotesting. 6.3 Final Hydrotest The water remaining in the pipeline at the end of the cleaning and flushing operations, including recovery of all pigs will be used as the water for the hydrotest. Pressurization starts after an initial stabilization of water temperature and pressure. The pipe segment will be pressurized according to the following:

The initial pressurization of the pipeline will be maintained for approximately 24 hours at a lower pressure to allow the system to stabilize. After this time has elapsed, the pipeline pressure will be increased to the final hydrotest pressure. 14 January 2007

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When a stable hydrotest pressure has been achieved, it will be maintained for the duration during which time the pipeline pressure and ambient temperature will be continuously monitored and recorded using pressure gauges, transmitters, and temperature probes. If it is necessary to prevent the pressure inside the pipeline from exceeding the maximum allowable pressure, water will be released in a controlled manner consistent with permitting requirements. Records of the volumes of injected water will be maintained. Minimum total test duration will be 8 hours per Table 841.322(f) in ASME B31.8, Gas Transmission and Distribution Piping Systems.

6.4 Hydrotest Failure In the event the pipeline system fails to hold the hydrotest pressure, all potential leak pathways will be determined and examined immediately. A pressure crosscorrelation will be performed to ascertain the extent and probable location of the leak(s). Instrumented tools, e.g., pigs with hydrophones or ROV deployed leak detection equipment will initially be used to locate the leak if suspected in a HDD segment. As a last resort, if these techniques are unsuccessful for the in water portion, then dye will be injected into the hydrotest water to help identify the leak location. The crew will therefore be available to perform any corrective measures that may be required. 7. DEWATERING 7.1 General After completion of the hydrotest, the pipeline will contain test water that must be removed. Since the base case for pre-commissioning is not to use water inhibition or chemical additives, water discharge is simplified. The only potential environmental concern will be sediment and suspended debris. These will be removed by filtration and the use of sedimentation pools or temporary holding tanks, before discharge into the environment. Water sampling and testing will be performed to ensure compliance with current environmental regulations and permits obtained for the project, which are in force in the relevant areas of discharge as described in Section 3.2. Displacement of the water from the pipeline section will be performed using dewatering pigs driven by dry compressed air. 7.2 Dewatering Runs The dewatering operation will continue until no further water is recovered. Dry compressed air is the medium used to propel the dewatering pigs. The average speed of the dewatering train will be in the order of 2 - 3 ft/sec. 7.3 Water Disposal Approximately 7,400,000 gallons of water will be discharged from the pipeline following a successful hydrotest of all sections. Approximately 149,000 gallons of 15 January 2007

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water will be discharged from the Susquehanna HDD Segment Hydrotest and approximately 27,175 gallons of water will be discharged following the hydrotesting of the Back River HDD Segment. 7.4 Dewatering Records Details of test water and other media disposed from the receiving end will be recorded. These include: Salt content of the last water batch at the receiving end, if applicable; For each de-watering run, the quantities, pressure and flow rate records of the driving medium; Water disposal information and composition For the final run, the dewpoint records of the air. The data recording requirements per applicable permit conditions. If the water from the pipeline, after water analysis has been completed, can be discharged without pretreatment, the test water will be released in an upland location through an energy dissipater which will flow into the Susquehanna River, in compliance with applicable permit limits. Any solid residue recovered during cleaning will be collected and disposed off at a licensed disposal site.

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8. DRYING Drying of the pipeline will be carried out immediately following dewatering. Various techniques can be used, including: Chemical swabbing; Air drying; and Vacuum drying. The use of the vacuum drying process is dependent upon a thorough dewatering and will be evaluated at a later date. Due to the length of the pipeline and its undulating profile, drying will be performed from both ends to reduce the drying time if the vacuum drying process is used. In order to reduce the drying time, however, it will be beneficial to use a combination of chemical swabbing, followed by air drying. The chemical swabbing using monoethylene glycol (non-volatile with a low vapor pressure) can be used in three slugs, separated by pigs. The entire train can be propelled by super-dry air. Upon recovery of the swabbing train, the glycol slugs will be sampled for water content. The used glycol will be recovered and recycled for further use on other projects, If AES chooses to dispose of the used glycol versus recycling it for reuse, then it will obtain applicable permits and dispose of it at an approved disposal facility. Dry air purging will then continue until the specified dew point for the pipeline is attained. 9. INERTING AND PURGING Following the drying operation, purging of the pipeline with nitrogen will be required prior to the introduction of natural gas. This is necessary to reduce the oxygen concentration and prevent mixtures of gas and oxygen that are combustible. Upon completion of the purging operation, the pipeline typically will be full of low-pressure nitrogen (between 10 and 30 psig). Purging will continue until the dew point at the discharge end remains below the specified dew point while replacing twice the content of the pipeline at purging pressure. 10. PLANT AND EQUIPMENT 10.1 Water Flooding Spread The pumping equipment will be located at one end of the pipeline. The water will be filtered through 50 micron filters and will be left in the pipeline for no more than 30 days. Prior to flooding, hydrotest heads will be fitted to both ends of the segment/section to be tested. These heads will allow the insertion and removal of pigs. A pig-launching station, which includes a filter and pump unit, will be installed at one end of the pipe segment. A temporary pig receiver, drain line and vents will be installed on the other end. A portable compression station with containerized units and portable offices will be located at the receiving end. All activities and equipment for the initial hydrotesting of the HDD segments will be confined within the temporary work areas designed for each HDD crossing. 10.1.1 Pipeline Hydrotests 17 January 2007

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The hydrotest of the entire pipeline segment will be conducted in two Test Sections. Testing equipment will be located on the west bank of the Susquehanna River. Pressure gauges will also be located at the facility end to monitor the hydrotest pressures. 10.1.2 Dewatering and Drying Air compressors will be placed at Sparrows Point to dewater towards the interconnection points. Drying will also be performed towards the interconnection points. The pipeline will then be purged with nitrogen from the Sparrows Point site in preparation for gas transmission. 11. ENVIRONMENTAL ASPECTS The internal surface of the pipeline will be coated with a protective film coating, which is generally nontoxic. However, Mid Atlantic Express will perform toxicity testing for the selected internal coating prior to coating the pipe. The results of the toxicity testing will be provided to DEP and DPEP for review. 11.1 Intakes The intake pipe will be installed with screens and filters and the intake velocity will be restricted to less than 2 ft/sec. This approach minimizes the potential for entrainment or entrapment of aquatic organisms. Prior to discharge of any water to State Waters, the water will be tested to ascertain if it is within the limits of the permit and within the limits for chemical concentrations specified in Maryland General Permit for Discharge of Hydrostatic Test Waters (COMAR 26.08.04.09.K), General Permit No 06HT. The discharge of water from the hydrotest of the offshore HDD segments will be conducted no less than 400 feet from any sensitive species. The filtered water when discharged is not expected to have a detrimental impact on marine biota. The intake velocity and aperture size of the intake screens will be designed to minimize the rates of impingement and entrainment, based on consultations with NMFS the screen size will be less than 2 mm. It is possible that organisms smaller than the aperture size of the screens and that swim at a slower rate than the intake velocity could be drawn in with the test water, while larger, slow moving biota could be trapped on the screens for the length of time it takes to fill the pipeline segment. To address potential impact to marine organisms and biota, the intake velocity of the system will be restricted to less than 2 ft/sec, with a flow rate of approximately 1,200 3,600 gallon/min so that the potential for entrainment of marine biota is minimized. The screen through which the water is drawn will be sized to minimize the rate of impingement on the screens while the pipeline is filling. As a result, minimal impact to marine biota will occur at the water intake locations. 11.2 Discharge It is not anticipated that additional chemicals will be required. Mid Atlantic Express will sample and test the water prior to discharge. If required, the water will be treated to the level required such that it complies with any and all licenses and 18 January 2007

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permits required for discharge and does not detrimentally affect the quality of the receiving waters. There is not expected to be a thermal impact to the discharge water body due to the discharge of water used in the hydrotest procedures. With regard to the hydrotests of the HDD segments, the water will only be retained in the segments for a short time and the volumes contained within the segments will be small enough that the thermal plume will be limited and will dissipate quickly.

The setback distances for hydrotest and leak test discharges were conservatively selected and are protective of nearby sensitive receptors due to the use of seawater in the test operations, absence of chemical additives and the use of intake controls and diffusers to control velocity during intake and discharge.
Each discharge location is shown in Table 1 and on the drawings included in Appendix D. 12. REFERENCES The following documents were utilized in the preparation of this document: 1. ASME B31.8, Gas Transmission and Distribution Piping Systems. 2. DOT 49 CFR Part 192, Transport of Natural and Other Gas By Pipeline Minimum Federal Safety Standards.

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APPENDIX A WATER VOLUME CALCULATION

TYPICAL WATER VOLUME CALCULATION FORMULA

V = L x ( 3.1416 x D2 / 4 ) x 12 / 231 Where: V = Gallons required to fill test section

L = Length of test section, feet D = Inside diameter of pipe, inches

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APPENDIX B MATERIAL SAFETY DATA SHEET FOR TYPICAL HYDROTEST WATER ADDITIVES AND SWABBING
BRIGHT DYES WATER TRACING DYE FLT YELLOW/GREEN PRODUCTS

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

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

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APPENDIX D HYDROTEST DISCHARGE LOCATION DRAWINGS

MP 43.6 MP 44.6 Linefill = 149,000 Gal Dewater following test @ MP 43.6, Tract 655, Harford County, Md. Section #2

HDD Mid-Atlantic Pipeline Crossing of Susquehanna River

MP 0.0 MP 43.6 Linefill = 7,400,000 Gal Dewater following test @ MP 43.6, Tract 655, Harford County, Md. #2 Test Section #2 Mid-Atlantic Pipeline

TYPICAL HYDROTEST DISCHARGE ENERGY DISSIPATOR

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