Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT H

Spill Prevention Plan

02:OO2398_CC12_04-B2311 H-l R_EMCP Segmenl.doc-2n9108

SPILL PREVENTION PLAN

Cross Hudson Project

Manhattan, New York

ENSR Corporation February 2008 Document No.: 10923~12·100

H-3 H-4 Spill Prevention Plan ENSR' AECOM Cross Hudson Project February 2008

TABLE OF CONTENTS

SECTION

CROSS REFERENCE CHECKUST III

SPP REVIEW LOG VII

CONSTRUCTION ADMINISTRATOR APPROVAL VIII

PROFESSIONAL ENGINEER CERTIACATION VIII

DISCHARGE RESPONSE REPORTING - QUICK REFERENCE SUMMARY .IX

1.0 INTRODUCTION 1

2.0 SITE DESCRIPTION 1

3.0 FAOUTY DRAINAGE AND MANAGEMENT OF RUNOFF 2 3.1 Topography 2 3.2 Surface Water 3 3.3 Direction of Flow 3 3.3.1 Upland Segment 3 3.3.2 Hudson River 4

4.0 OIL STORAGE OPERATIONS 4 4.1 Refueling Protocols 5 4.1.1 Land-Based Equipment 5 4.1.2 Marine Equipment 5 4.2 In-Process Use Oils 6 4.2.1 cable Installation 6

5.0 LOADING/UNLOADING PROCEDURES 7 5.1 Bulk Fuel Transfer 7 5.2 Drum Transfers 8

6.0 INSPECTIONS AND RECORDS 9

7.0 SECURITY 9

8.0 PERSONNEL TRAINING 10

9.0 EMERGENCY RESPONSE 10 9.1 Emergency Equipment 10 9.2 Emergency Procedures 11

10.0 NOTIFICATIONS 13 10.1 Oral Notifications 14 10.2 Written Notifications 14

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11.0 SUBSTANTIAL HARM 16

12.0 PLAN AMENDMENTS 16 12.1 Plan Review 16 12.2 Professional Engineer (PEl certification 16

13.0 ENGINEERING DEACIENOES 17

APPENDICES

Appendix A sampleInspection and Reporting Forms & Spill Response Equipment AppendiX B Sample SPP Training Outline

Appendix C certification of the Applicability of the Substantial Harm Criteria

Appendix D Tables Table 1-1 Emergency Contacts Table 4-1 Oil Source Summary Appendix E Site Plan Figure

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H-6 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008

CROSS REFERENCE CHECKUST

4OCFIl112 Reclulrilmenbl spp 5ectIon . section " SUb rt A':'~ IIC!1blj~ii~nJtlliia;.l &...l:~~~rgt~I\:~lltIi'~AI/Typei of\OIlll ~ , . Pi ',' , " .--• - ,'," - ,f",,,,(,,'f,,: -: ';!i\;:i1 .', ,-\-;""-,,/.,,." "/;;-' , .," '-: General applicability and exclusions: Non-transportation related facility that uses oil in quantitiesthat could be expected to discharge oil quantities that may be harmful to navigable waters of U.s, or adjoining shorelines must implement an SPP, Does not apply to: • Equipment not subjectto 311(j)(1)(C) of CWA • Facility not reasonably expected to havea discharge of oil N/A Equipment subjectto authority of USOOT 112,1 • General Total underground storage S 42,000gallons • Information Total aboveground storage S 1,320gallons • Only • Containers with capacity of < 55 gallons • UST/ancillary equipmentsubjectto technical requirements of Part 280/281 • Facility used exclusively for wastewater treatment (production, recovery, recycling of oil is not treatment) Key Definitions: BulkStrJr.Jge Container- container used to storeoil, used for purposes including the storage of oil prior to use, while being Used, or prior to further distribution in commerce, Oil-filled electrical, operation, or manufacturing equlprnent is not a bulk storage container. N/A

112.2 Navigable Wale

112.3(f) Requests for Extensions: EPA may authorize extensions to plan deadlines. N/A ... 111 H-7 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008

CROSS REFERENCE CHECKUST

40CFR 112 Requirements . Spp 5ectIon 5ectIon

Significant Spill Reports: SignifICant oil spills to navigable waters require filing of a report to EPAand the State (include information in 112.4). Significant spills include single 10.2, 112.4 discharges> 1,000 gallons or two or more discharges> 42 gallons within 12 month period. Appendix B

The SPP may be required to be formally amended and submitted to EPA for approval. I Amendments: Plan review and evaluation required every S years. Necessary amendments (i.e., those that include more effective prevention and control technology) must be made 112.5 within 6 months and the updated Plan must be implemented within 6 months of the update. 12.0 Document these reviews and include in Plan. A Professional Engineer must certify technical amendments. Management Approval: Plan must have full approval of management to commit the 112.7 Page V necessary resources to fully implement the Plan. Cross Plan Elements - Confonnance: Include discussion of facility's conformance/ compliance reference 112.7(a)(1-2) with applicable requirements. Checklist 1.0 Plan Elements - Facility Diagram: Describe physical layout of facility and include facility 2.0 112.7(a)(3) diagram. Diagram must show: location and contents of each container; completely buried tanks; transfer stations; connecting pipes. Rgure 1-1

112.7(a)(3)(i, iii), Plan Elements ­ Storage and Control: Discuss type and amount of oil in containers, 4.0 & (b), (c) controls (e.g. secondary containment), and other structures. Table 4-1

Plan Elements - Discharge Prevention: Discuss discharge prevention including 4.0& 112.7(a)(3)(ii) procedures for routine handling of products (loading/unloading). Table 4-1

Plan Elements - Countermeasures: Discuss countermeasures fordischarge recovery, 112.7(a)(3)(iv-v) 9.0 response, and cleanup (include methods of disposal/recovery).

Plan Elements - Notifications: Include contact list and phone numbers for facility 112.7(a)(3)(vi) response coordinator, National Response Center, cleanup contractors, and appropriate 10 Federal, State, and local agencies who must be contacted.

Plan Elements - Emergency Response: Provide procedures to enable a person to 112.7(a)(4-S) 9.2 respond to a discharge and report necessary information.

Plan Elements - Facility Drainage: Include prediction of direction, rate of flow, and 112.7(b & c) quantity that could be discharged as a result of major equipment failure. Provide 3.0 appropriate containment and/or diversionary structures or equipment.

plan Elements - Non-Conformance: If conformance is not practicable, explain why and provide an oil spill contingency plan (per Part 109) along with a written commitment of 112.7(d) N/A personnel, equipment, and materials required to control and remove any quantity of oil discharged that may be harmful.

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CROSS REFERENCE CHECKUST

- 40CFIt 112 Requirements Spp section section

Plan Elements - Inspections, Tests, and Records: Conduct inspections, tests, and 112.7(e) records in accordance with written procedures developed for the facility. Maintain records for 6.0 3 years.

Plan Elements - Training: At leastannually, train/brief oil handling personnel in 112.7(f)(t,3) 8.0 equipment/facility operations, discharge procedures, applicable regulations.

Plan Elements ­ Designated Individual: Designate a person who is accountable for 112.7(f)(2) 2.0 discharge prevention and who reports to facility management.

Plan Elements - security: Ensure your facility hasadequate security to prevent vandalism and respond to emergencies: • Fence oil storageareas and lock/guard when facility is unattended. 112.7(g)(t-5) • Ensure masterflow valves and valves pennilting outward flow remain closed. 7.0 • Lock starter controls in 'off" position and allow access to authorized personnel. • Securely cap or blank-flange loading/unloading connections of piping. • Provide facility lighting.

Plan Elements ­ loading/Unloading: Design loading/unloading areas to containthe lt2.7(h)(I) 5.0 maximum capacity of any single compartment of a tank car/truck.

Plan Elements - Loading/Unloading: Provide interlockwarning light or physical barrier 112.7(h)(2-3) system (e.g., wheel chocks) to preventvehicle departure beforedisconnection of transfer 5.0 lines. Priorto filling/departure, closely inspect vehicle.

Plan Elements - Repairs: Evaluate aboveground container if it undergoes a 112.7(i) 6.0 repair/alteration or a change in service that might affect riskof discharge.

Plan Elements - Conformance, Additional Regulations: Include discussion of 112.7(j) 1.0 confonnance with morestringent State rules, regulations, and guidelines.

Requirements for Petroleum Oils and N"n"Petroleum Oils, Except animal Fats and Oils and G~ and fish and Marine Mammal Oils; and Vegetllble Oils (Including 01l.1roIn Seecb,.Nuts, Fruits, and Kernels): .­ , ",..; "

112.8(a) Meetgeneral requirements listed underSect. 112.7. (see above)

Plan Elements - Facility Drainage: Diked areas ­ drainage must be manual, keep bypass valveclosed, inspect retained rainwater, open the bypass valve and reseal it 112.8(b)(1-5) following drainageunder supervision, keep records. Undiked areas With a ootential for a 3.0 and (c)(3) discharoe ­ designflow so oil is retained or returned to facility, provide redundancy for pumps used to treat drainage.

v H-9 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008

CROSS REFERENCE CHECKUST

40CFR 112 . Requirements Spp section section

Plan Elements - Above Ground Bulk Containers: Containers must becompatible with 112.8(c}(1-2} the material stored and conditions of storage such as pressure and temperature. secondary 4.0 containment must be provided. Plan Elements - Underground Bulk Containers: Protect buried metallic tanks installed 112.8(c}(4-S} on or after Jan. 10, 1974 from corrosion by coatings and regularly leak test. Protect partially 2.0,4.0 buried or bunkered tanks. I Plan Elements - Above Ground Bulk Containers Testing: Perform visual and non­ destructive integrity test on regular basis and when repaired, and keep records. Include 112.8(c}(6} 6.0 supports and foundations. Frequently inspect containers (exterior) for deterioration, discharges, or accumulation inside containment.

Plan Elements - Internal Heating Colis: Monitor or control steam return and exhaust 112.8(c}(7} N/A lines if discharging to water body.

Plan Elements - Bulk Container Controls: Provide good engineering practices, including one of the following: high liquid level alarms; high liquid level cutoff; audible or 4.0& 112.8(c}(8} code signal communication during loading/operation; sight gauge (or equivalent), Regularly Table 4-1 test liquid level sensing devices.

Plan Elements - Inspections: Observe effluent treatment frequently to detect system 112.8(c}(9-10} 6.0 upsets. Promptly correct visible discharges from containers/equipment.

Plan Elements - Portable Containers: Position to prevent discharge and provide 4.0& 112.8(c}(11} secondary containment Table 4-1

Plan Elements -PIping: Provide buried piping installed or replaced on or after Aug. 16, 2002 w/ protective wrapping and coating. Design pipe supports to minimize abrasion and N/A 112.8(d)(1-S) corrosion and allow for expansion and contraction. Regularly inspect aboveground valves (refer to and piping. Cap or blank-flange the terminal connection at the transfer point. Warn vehicles section 2.0) of aboveground piping or other oil transfer operations.

Sections of40 CFR 112 that are not listed aboveare not app/icable.

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spp REVIEW lOG

The purpose of this log is to record the frequency of Plan review and identify when an amendment is required.

Arl1endment Date Of 5 Required? Date Next Person Completing Review Review (Indicate Yes If Amendments Are Required, ProvIde DetaIls Review Is OrNol R.... ulred Brief reason for amendments: Printed Name: Plan must be amended by (date): Printed Title: Is PE certification required (indicate yes or no)? Sionature: Brief reason for amendments: Printed Name: Plan must be amended by (date): Printed Title: Is PE certification required (indicate yes or no)? Sionature: Brief reason for amendments: Printed Name: Plan must be amended by (date): Printed Title: Is PE certification required (indicate yes or no)? Sionature: Brief reason for amendments: Printed Name:

Printed Title: Plan must be amended by (date):

Signature: Is PE certification required (indicate yes or no)?

VII H-Il Spill Prevention Plan ENSR Cross Hudson Project February 2008

CONSTRUCTION ADMINISTRATOR APPROVAL

I certify that this document and aU attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. CHC is committed to the prevention of discharges of oil to navigable waters and the environment, and maintains the highest standards for spill prevention control and countermeasures through regular review, updating, and implementation of this Spill Prevention Plan ("SPP") for the site.

This SPP wiU be implemented as herein described.

Nameand Title: Company: CHC

ROFESSIO GINEER CE TIFICATION

I hereby certify that I have reviewed this plan, and attest to the following:

r I am familiar with the provisions of 40 CFR Part 112;

~ I, or my agent, have visited and examinedthe site;

r This SPP has been prepared in accordance with good engineering practices, including consideration of applicable industry standards, and with the requirements of 40 CFR 112;

r Procedures for inspection and testing have been established in this SPP; and

r This SPP is adequate for the facility.

In preparing the SPP, I have relied upon plans, drawlnqs, information, and calculations completed by Cross Hudson personnel, and personnel working under my direction in reviewing the SPP.

Printed Name of Registered Professional Engineer

ignature of Registered Professional Engineer

Registration No: 08 \\0(0 State: --'---1---­

vni Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

DISCHARGE RESPONSE REPORTING - OUICK REFERENCE SUMMARY

1. Extinguish all sources of ignition. 2. Isolate incompatible or reactive chemical substances. 3. Isolate all potential environmental receptors including drains, sumps, soil, etc. 4. Determine if the discharge is incidental' or non-incidental': • Discharges include, but are not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil that is not otherwise permitted under other programs. o For incidental discharges - attempt to stop or contain the discharge at the source without endangering yourself or others. o For non-incidental disdlarges - immediately report the discharge to the Cross Hudson representative. 5. Reporting to outside agencies - CHC representatives will conduct necessary reporting to outside agencies. • If a discharge of oil or hazardous material has entered the environment - report to New York State Department of Environmental Conservation C'NYSDEC"). • If a discharge migrates off of the construction site, report to the Local Fire Department. • If a discharge enters the sewer system, report to Department of Environmental Protection. • If a discharge causes a sheen or discoloration of navigable waters or adjoining shorelines - report to the National Response center C'NRC"). 6. Recover material discharged and clean up discharge area. 7. Decontaminate tools and equipment, Collect all rinsate and debris. 8. Dispose of waste materials in accordance with all applicable regulations and Cross Hudson procedures. 9. Cross Hudson representatives will conduct follow-up written notifications to applicable agencies. 10. Cross Hudson representatives will coordinate an lnddent analysis with the involved parties to develop plans necessary to prevent recurrence.

1 Based on guidance contained in the Spill Guidance Manual published by NYSDEC, "Incidental" discharge is defined as a discharge which meets ~ of the following criteria: 1) The quantity is known to be less than S gallons; 2) The discharge is contained and under the control of the fadlity; 3) The discharge has not and will not reach the state's water or any land: 4) The discharge is cleaned up within 2 hours of discovery. A discharge is considered to have not impacted land if it occurs on a paved surface such as asphalt or concrete. A discharge in a dirt or gravel parking lot is considered to have impacted land and is reportable.

2 "Non-incidental" discharges are those discharges that fail any of the above criteria for incidental discharge and any amount that impact environmental receptors. The Independent Inspector will conduct external notification and reporting as required to regulatory agencies and/or first-responders.

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1.0 INTROPUCTION

The Cross Hudson Project involves the construction of a 670 MVA, 345 kV AC electric generator lead connecting the Bergen Generating Station in Ridgefield, to the (ConEd) West 49"' Street Substation in New York City. The cable System will be composed of one (1) underground Alternating Current ("AC") circuit that will originate at a 230-345 kV switchyard to be constructed at the Bergen Generating Station. The Project consists of installing cables along a corridor approximately 8 miles in length, of which approximately 3.5 miles will be located on land in New Jersey, 4.0 miles beneath the Hudson River, and 0.5 miles in New York City C'NYC").

The segment lndudes those portions of the Project between the West 49"' Street Substation connection and the temporary cofferdam at the end of the HOD borehole. The cable system will be composed of self-Contained Fluid Filled ("SCFF") cable installed in underground conduits and duct banks. Using site-appropriate construction techniques, the undergrOUnd cable system will be installed along the indicated route between Bergen Generating Station and the Hudson River. The cable system in the Manhattan 5egment consists of two components: a water component and a land component. The water component will be buried in the bed of the Hudson River Within conduits installed by horizontal directional drilling ("HOD"), and will make landfall in New York City between Piers 94 and 95. The land component uses site-appropriate construction techniques, including HOD (where the land component meets the water component) and conventional trench and cover techniques, the cable system will be installed from the area where landfall is made to the ConEd West 49"' Street Substation. In addition to the three main conductors, the system includes two fiber optic cables for monitoring, relaying, and communication purposes. The land installation will also include a distributed temperature sensor ("DTS").

This Spill Prevention Plan ("SPP'1 contains infonnation pertaining to the prevention of spills, containment of spills, response and dean-up measures, and reporting procedures for the construction of the Manhattan Segment of the Cross Hudson Project.

This plan meets the spill prevention and planning requirements of the United States Environmentai Protection Agency's ("US EPA") Oil Pollution Prevention Regulations (40 CFR 112). A Cross Reference Table has been provided at the beginning of this SPP for the convenience of the reader should the format of the SPP deviate from the sequence specified in 40 CFR 112.

2.0 SITE DESCRIPTION

1. Name of construction site: CHC

2. Type of construction site: Construction of a 670 MVA, 345 kV AC electric generator lead

3. Location of construction site: New York Oty (Manhattan), NY

4. Maximum oil stol'ilge/handling capadty: Approximately 3,000 gallons

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H-tS Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008

5. Normal daily oil capacity: Varies (dependent on construction activities)

6. Name and title of person accountable for spill prevention, control and countermeasures at site: Kiewit Construction Company PM Fred Hammel

7. Spill History: Historic spill information and soil and groundwater conditions are presented in the Environmental Management and Construction Plan C'EM&CP").

8. storm water runoff flow prediction: Referto Rgure 1-1

9. sensitive receptor(s): Hudson River

This SPP includes the oil containing equipment located at the Cross Hudson site that either stores or uses oil in quantities of 55 gallons or greater. Oil containing equipment located at the site that contains less than 55 gallons of oil (l.e., various pieces of machinery, portable containers, and tanks) is exempt from the requirements of this SPP. Table 4-1 contains a summary of all oil containing devices and storage containers that are subject to the provisions of this SPP.

All petroleum spills must be reported to the NYSDEC within two hours of discovery, except those which meet all of the following criteria:

• The quantity is known to be less than 5 gallons: and • The spill is contained and under the control of the spiller: and • The spill has not and will not reach the State's water or any land: and • The spill is cleaned up within 2 hours of discovery

Workers will be informed of these notification requirements and will report any spill to the project foreman immediately after discovery.

Site plans were developed in accordance with the requirements of the SPP regulations. Figure 1-1 provides a site plan for Cross Hudson that includes the locations of storm drains and site drainage (refer to Section 3.0 for a detailed discussion).

3.0 FACILID DRAINAGE AND MANAGEMENT OF RUNOFF

3.1 TooograPhy

The construction site is located on relatively flat terrain located in an urban setting. The majority of the construction will occur in developed, paved areas. The Hudson River is located to the west of the site. The site is not located in or around any wetland areas.

The cable system will make landfall in New York aty between Piers 94 and 95. The Manhattan Segment Project Area generally consists of developed properties with impervious surfaces. 2

H-I6 Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

The Project Area elevations range from approximately 8 feet North American Vertical Datum 1998 (NAVD88) where the cable makes landfall to approximately 20 feet NAVD88 in the vicinity of the ConEd West 49'" Street Substation. At the location where the Splicing Chamber will be constructed, elevations range from approximately 13-20 feet NAVD88. Along the upland cable route between the Splicing Chamber and the ConEd West 49'" Street substation, elevations range between approximately 16-20 feet NAVD88.

3,2 Surface Water

The major surface water resource in the vicinity of the site is the Hudson River, which is located approximately between SO feet and 200 feet west of the western boundary of the site. The Hudson River flows in a southerly direction and empties into New York Harbor.

3,3 Pirectlon of Flow • 3,3,1 Upland Segment

If there is a release to the environment at this construction site, the most likely environmental receptor potentially affected by the release is paved surfaces or exposed soil if a spill occurs adjacent to an excavation. Surface drainage from the construction site occurs by overland flow from higher terrain to the adjacent lOW-lying areas. Storm drains, which are located throughout the site, are also possible receptors.

Releases Within the paved surfaces, splicing and dielectric fluid chamber and the ConEd West 49'" Street Substation would be retained by the impervious floors and walls of these buildings and detected by construction personnel for subsequent cleanup. Table 4-1 provides a summary of secondary containment and engineering measures designed to reduce spill potential.

Small containers of oil (less than SS gallons) may be stored and used throughout the site. The threat of release from these containers is greatest. during relocation or use by the Contractor who would immediately observe and report a release and take response actions using absorbent material and/or drain coversto divert oil from storm drains.

Control and containment measures that reduce the likelihood that oil will impact surface water bodies in the event of a spill will be implemented. Table 4-1 summarizes all oil containing equipment and storage locations, containment measures, as well as the most likely route of exposure and pollution prevention strategies designed to minimize exposure. If stormwater collects in any secondary containment area, it will be visually inspected for evidence of an oil leak (t.e., visible sheen) before being manually removed.

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There are a number of stonn drains, designed to collect stonnwater runoff, located along the proposed construction route. The majority of stonnwater runoff is directed to the Hudson RiVer, the local drainage outletfor Manhattan.

3,3,2 HUdson Riyer

Any spills that occur from marine vessels or as a resultof cable installation operations that occur in the river will directly impact the Hudson River. All marine vessels will be equipped with spill control measures and staffed with trained personnel in the event of a spill.

4,0 OIL STORAGE OPERATIONS

This section describes oil storage and oil-rontaining equipment at the site. The material and construction of each container is compatible with the material stored and conditions of storage. Individual portable containers (l.e., 55 gallon drums) are not depicted on the site plan, but locations where these portable containers are typically stored in significant quantities are identified. Oil loading and unloading procedures aredescribed in detail in section 5.0.

COnstruction phase oil storage and containment will be limited to minimal quantities stored in temporary containers located within the designated staging area and to those oils associated with non­ transportation related, heavy construction equipment, hereafter referred to as "in-process use" oils. Details regarding the storage capacity, type of oil and othermaterials, and containment capacity for volumes of at least55 gallons that are present in tanks, containers, or various devices are provided in Table 4-1.

If a release of oil were to occur from tanks, containers, or process equipment, the amount of material spilled would depend on the size of the container and the type of release. Total materials released could range from a few drips to approximately 1,000 gallons, and the maximum rate of flow could be the instantaneous (complete failure of the container or device) release of 1,000 gallons. Spills occurring during the construction of this Project have the potential to impact a surface water body (see section 3.0).

Contractors will comply with the follOWing standards for the storage of oil:

• Maintain copies of materials safety data sheets on-site. • All applicable state, local and federal regulations covering the transport, storage and handling ofoil. • Fuels and other controlled materials will be stored in designated areas. All such areas will be at a minimum, 100feet from any water body, watercourse, wetland or known spring or well.

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H-18 Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

• Above ground tanks will be equipped with secondary containment devioes (l.e., double walled fuel tanks). Oil will be kept in restricted access areas and kept separate from other construction activities. • All yards and storage areas shall be equipped with sufficient supplies of spill control and absorbent materials for the volumes present. • Spill control supplies will be clearly marked, readily accessible, and personnel will be instructed on their use prior to the initiation of construction.

4,1 Refuelina protocals

4.1.1 Land-Based Equipment

Refueling of construction equipment on-site will occur on a staging area or directly in the construction area. Fuel oil will be brought onto the construction site as necessary. A permanent fueling station is not proposed at this time. If a temporary fueling station is required, a double walled refueling tank will be placed on site on top of an impenneable surface (le: concrete or pavement) to prevent discharged fuel from reaching a navigable water. The materials and construction of the temporary refueling tank will be compatible with the storage of fuel(s) dispensed (i.e., gasoline, diesel, etc.). The temporary refueling tank will be firmly secured into the substrate supported by an appropriate foundation to prevent settlement.

Other oils associated with oil-containing construction equipment, such as lubricating oils and hydraulic oils, will also be brought onto the construction site as necessary or will be stored in containers within a fuel and oil storage building. The material and construction of each building will be compatible with respect to the material stored and ambient storage conditions. The contents of all tanks and containers of various oils Within this building will be kept at ambient temperature and pressure.

In order to prevent vehicle departure before complete disconnect of fleXible or fixed transfer lines, the fuel delivery truck driver will remain with the refueling vehicle at all times during the fuel transfer process. Additionally, prior to filling and departure of any tank car or tank truck, the delivery truck driver shall notify appropriate site personnel so that the lowermost drain and all outlets of such vehicles will be closely examined to prevent liquid leakage while in transit. Instructions will be provided to bulk oil delivery truck drivers for loading/unloading procedures.

4,1,2 Marine Equipment

It will not be necessary to refuel the barge that is in the river. However, equipment located on the barge may require refueling. In the event that refueling becomes necessary, a refueling barge would be sent to the barge in the river, and a refueling hose would be passed from the

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H-19 Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

refueling barge to the construction barge. Any operations refueling will be subject to US Coast Guard regulations.

4,2 In-process Use Oils

In-process use oils associated with non-transportation related, heavy construction equipment and other oil-containing devices have the potential to be released as they maneuver and operate throughout the construction site. The proposed schedule for construction operations is detailed in the EM&CP for the Project.

The nature and volume of oils contained within construction equipment are typical for construction operations of this scale and include diesel fuels, lubricating oils, and hydraulic oils. All heavy construction equipment will be equipped with spill response materials such as absorbents to contain material that may be inadvertently released. Temporary, construction-phase sheds or job boxes with spill response kits will be located in an area adjacent to the refueling station or other appropriate locations throughout the proposed project area. All heavy construction eqUipment supervisors will be adequately trained in emergency spill response procedures and familiar with this SPP document (see 5ection 8,0).

Inspections of non-transportation related, heavy construction eqUipment are conducted at least weekly and during each visit to the refueling station for any leakage of oils. All observations are recorded in an inspection log (refer to the sample log contained in AppendixA).

Table 4-1 summarizes exterior oil storage and oikontaining equipment at the site, and provides location, equipment capacity, the most likely route of exposure, and secondary containment, engineering controls, and pollution prevention strategy in case of a spill.

4,2.1 Cable Insta"ation

The Cross Hudson Project includes the installation of one 345 kV AC generator lead, consisting of three SCFF cables. Each of the cables is filled with apprOXimately 1,000 gallons of dielectric fluid. During installation, the upland and submarine cable types must be spliced together in a Splicing Chamber.

Splicing of the Cross Hudson Project cable takes place underground, in a controlled environment. The splicing is performed in the splicing chamber, which is a contained concrete vault. A minor quantity of dielectric fluid could be spilled, but would be contained within the splicing chamber. The environment around the splicing chamber is also controlled, usually with the use of a tent or tarp to cover the area.

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H-20 Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

Inspections of non-transportation related, marine construction equipment will be conducted at least weekly and during each visit to the refueling station for any leakage of oils. All observations are recorded in an inspection log (refer to the sample log contained in AppendiX A). Table 4-1 summarizes exterior oil storage and oil-containing equipment at the site, and provides location, equipment capacity, the most likely route of exposure, and secondary containment, engineering controls, and pollution prevention strategy in case of a spill.

5.0 LOADING/UNLOADING PROCEPURES

Fueling operations at the site are handled by the Contractors, who are responsible for fuel deliveries for diesel, No. 2 fuel oil, and unleaded gasoline. All tanks are filled from tanker trucks. Personnel observing filling are required to verify that adequate tank capacity is available prior to unloading to minimize the likelihood of tank overfills. Personnel are provided with both formal and on the job training in all aspects of fuel deliveries. Cross Hudson employees have also received training in spill control measures and proper reporting procedures in the event of any equipment malfunction and/or spill.

When refueling equipment during construction the follOWing standards will be applied:

• Equipment refueled in yards shall be refueled in a clearly marked and designated refueling area; • Designated refueling areas will be located on impenneable surfaces to contain spilled oil, fuels or lubricants; • Care will be exercised at all times to prevent overfilling; • When refueling, all fuel trucks, portable drums and tanks will be inspected for leaks or signs of wear; and • All refueling trucks will carry spill containment materials, and the driver/operator will be trained in their use and responsible for their employ after spills.

No refueling will be perfonned witllin 100 feet of any wetland, stream, known well or spring. The only exception to thls prohibition will be portable water pumps and barge fueling activities.

5.1 Bulk Fuel Transfer

When fuel is transferred from a tank truck, the driver will park in the appropriate staging area. The fill connection for each tank is located witllin a secondary containment area and a spill bucket is placed beneath connections during loading operations. Should a transfer hose fail during the loading process, fuel would not be released from the tank since it is loaded into the top of tank, above the liquid level. If at any time a release oa:urs, transfer operations will be stopped immediately and spill response measureswill be impiemented.

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H-2l Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

Thefollowing steps describe the delivery prooedures for bulk fuel:

1. Drivers delivering fuel must inform the appropriate Contractor of their presence on site. The Contractor will verify that adequate tank volume is available for the delivery. No unsdleduled fuel deliveries can be made to the facility. 2. The Contractor will assist the driver and oversee the delivery. 3. The driver mustpark the truck in the appropriate unloading area. 4. The driver mustinform the Contractor of the location of the emergency stop switch that will stopthe transfer pumpon the truck. 5. The handbrake must be set and the truck wheels are chocked to prevent movement of the vehicle prior to disconnecting hoses. 6. Drip pans must be placed beneath each ronnection or valve of the truck and under the fill ronnection. A spill box, rontainment, or permanent spill bucket is used to control any minor leaks from the check valve and fill pipe. 7. The driver must make the appropriate ronnections from the truck to the storage tank fill port, and the Contractor will monitorthe operation. 8. After the previous steps have been taken, the driver can transfer the fuel. During transfer, the driver andthe Contractor mustcarefully observe the truck and hose. 9. Upon rompletion of the transfer, the driver will ensure that the transfer hose is empty before disconnecting. If any fuel is spilled, cleanup will begin immediately. 10. Any fuel rollected in the drip pans will be transferred to the proper waste rontainers in the storage area. 11. The Contractor will ensure that the fill pipecap has been re-secured. 12. Only after allthe steps described above have been satisfactorily rompleted will the driver be allowed to movethe vehide and leave the site.

5,2 prum Transfers

When materials are transported on-site using a forklift, either a drum attachment is used or containers are secured to pallets on the forklift to prevent the containers from falling during movement. If a barrel dolly is used, the operator will ensure that the barrel is compatible with the dolly and that the barrel is properly secured to the dolly. The following outlines delivery and transport procedures for small containers:

1. Containers are checked for damaged areas or signs of corrosion, If any is detected, the rontainercontents aretransferred to an appropriate rontainerand labeled prior to moving.

8

H-22 Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

2. Cross Hudson personnel ensure that containers aresecurely closed prior to moving. 3. Containers are secured on forks or pallets when using a forklift or properly secured when using a dolly to prevent containers from falling during movement

6,0 INSPECTIONS AND RECORDS

Inspection procedufes have been developed for oil storage areas to prevent or qUickly detect signs of oil leakage, equipment malfunction, structure deterioration, and depletion of spill control equipment If a repair or alteration will affectthe risk of discharge, additional tank evaluations will be considered. Key personnel at the site who are familiar with locations and type of equipment conduct periodic inspections of all oil­ containing equipment and storage containers included in this SPP. Other properly trained personnel may assist with inspections, asneeded.

Inspections and maintenance procedures will be conducted at weekly intervals and after each precipitation event to evaluate storage areas for the presenoe of oil and to observe the integrity of the equipment. If storm water accumulates nearany of the oil storage areas, the storm water will be visually inspected for any evidenoe of sheen prior to removal. The observations of each inspection and any remedial action taken will be recorded in an inspection log. If there is no Visible sheen present on accumulated storm water, removal procedures will entail manually activated pumping of discharge into the site's drainage system. The presence of a visible sheen on the accumulated storm water is evidenoe of a spill and will trigger appropriate response actions. In addition to routine inspection of temporary fuel tanks and oil storage areas, inspections also review, and replenish if necessary, the contents of spill response kits located throughoutthe site.

A copyof this SPP, including records of all inspections and tests, will be maintained on site. All records of visual inspections will include the follOWing information, where appropriate:

• Date and time of inspection; • Typeof inspection (visual, hydrostatic, etc.); • Signature of the inspector; • Results of the inspection, including remedial actions necessary; • Remedial or preventative actions taken; and • Explanation of why remedial actions were not completed, if applicable.

Z,O SECURITY

Cross Hudson's Contractor will monitor conditions on the site during all working hours. Access to sensitive areas is controlled to prevent unauthorized entry. Theconstruction area is well lit at night, and lighting is

9

H-23 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008 adequate for the identification of spills and prevention of spills through vandalism. All oil-

8,0 PERSONNELTRAINING

All personnel that might be involved in the discovery of and response to a release of oil at the site will be familiar with this SPP, the nature of oils contained on-site that could be released, and the location, use, and maintenance of site spill response equipment To protect human health and the environment, a training program will be conducted to ensure that spill response personnel understand the hazards associated with ali materials with the potential for release and applicable emergency response regulations.

SUpervisory training (including that for Emergency responders) will be conducted to ensure that personnel responsible for implementing the activities described in this plan, or who are otherwise responsible for oil poliution control, are familiar with the components and goals of this plan. Personnel wili be trained as appropriate for their job duties, on good housekeeping measures, proper operation and maintenance of equipment, proper handling procedures for oil and waste oil, and procedures to foliow during an emergency. The purpose of the training is to ensure that discharges are prevented and spili response procedures are reviewed. Training may be provided in a formal dassroom type setting, as on-the-job training, or during safety meetings as appropriate. Spill response procedures and signs will be posted at the facility providing spill response equipment location.

Furthermore, training sessions will be conducted after any release and response to a release has occurred.

9,0 EMERGENcy RESPONSE

Ali spilis are to be reported to the Cross Hudson representative. Smali, contained spills wili be addressed by the Contractor. Large spills and those involving flammable material may require the assistance of outside agencies.

The foliowing sections describe the emergency equipment maintained at the facility and the procedures the Contractor will take in the eventof a release of oil.

9.1 Emergency Equipment

The Contractor will store absorbent materials (i.e., spill pads, socks, booms, etc.), empty 55ijallon drums, brooms, shovels, and personal protective equipment (PPE) on site to handle incidental spills. The spill response equipment is stored near construction equipment, on marine vessels, and in lockers throughout the construction site. Response personnel can qUickly access spill response equipment to facilitate qUick responses in the eventof a spill. On a monthly basis, the Contractor will to

H-24 Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

verify that there is adequate spill response equipment to mitigate incidental spills. Generally, oil spills greater than 55 gallons are handled by a licensed spill response and waste removal.contractor,

Absorbent materials may be used to contain spills and prevent oil from reaching navigable waters. The Contractor may set up absorbent materials based on the direction of the oil flow and the volume of oil that is released.

The Contractor will maintain an adequate supply of on-site to control spills of hazardous materials, which may be used during construction activities, including:

• Sorbents, including pillows, wipe sheets and sawdust. • Commercially available spill kits (or equivalent) to handle spillsof varying sizes. • Shovels or small backhoes for the excavation of contaminated soils or materials. • Drums, barrels and other temporary storage containers for the clean up and transport of contaminated materials. • Absorbent pads for placement understatic machinery large enough to handle a complete loss of engine oil or hydraulic fluid. • Small sorbent kits for all vehicles and machinery.

In addition, the Contractor must stock the follOWing equipment when conducting waterborne activities:

• Rapid deployment fire proof/fire resistant oil containment floats and booms. The minimum length of booms should be sufficient to surround the work area and vessels. All booms will conform to USDOT and US Coast Guard requirements. • Oil removal or skimming equipment should be on hand or on call, inclUding oJephilic and hydrophobic absorbent booms or mats and/or mechanical skimmers. • sampling equjprnent of sufficientamounts to enable 24- hour monitoring if necessary.

When conducting waterborne activities, the Contractor must also stockor have access to dispersants, dispersant delivery platforms (i.e., aerial or marine), loading facilities, communications, etc. A list of spill response equipment is provided in Appendix A of the SPP.

9.2 Emergency Procedures

The responsibility for control and dean up of small 011 spills lies primarily with the COntractor, which will employ properly trained personnel to support oil spill dean up operations as required. If a spill presents an immediate hazard to personnel safety or the environment or is too large and cannot be handled by on-see personnel, spill response contractors may becontacted by the Cross Hudson representative.

II

H-25 Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

• The Doss Hudson representative will coordinare any and all decision making for spill containment and removal with Stare and Federal authorities (listed in Table1-1).

If a release of oil from a tank or containeroccurs, tne following actions will be taken:

1. The Contractor will stop oil transfer operations or container movement (if applicable) until the release is stopped andoil spilldebris material is removed. 2. The first person discovering any release of oil is responsible for securing the area and notifying the Doss Hudson representative to determine tne appropriate course of action for containment and removal of tne oil and waste material, If necessary, a licensed contractor maybe contacted. 3. Other Emergency Response Personnel (listed in Table 1-1) will be contacted as necessary. 4. The Cross Hudson representative will function as Incident Commander until relieved by a representative of a response agency) and will:

• Notifythe Contractor of hazards caused by the spill;

• Take appropriate measures to cope with tne emergency; and

• Order staff evacuation, if necessary (in conformance witl1 tne procedures outlined in tne emergency evacuation plan). Evacuations of parties other tnan tne contractor's own personnel will be determmed by local authorities.

5. TheContractor is responsible for securing tne incident scene and directing traffic awayfrom the area until relieved by the appropriate emergency personnel. 6. If derermined to be safe, trained personnel will take immediare steps to stop tne discharge and begin clean-up operations using mechanical methods (l.e., shovels, brooms, absorbent materials, etc.),

Procedures for containment and clean upof oil spills include:

• Removal of all sources of ignition from the spillarea;

• Donning of appropriate PPE (i.e., rubber boots andworkgloves);

• Focusing effortson preventing the oil from spreading from tne area into drainsor warerways;

• Applying absorbent materials for NO.2fuel oil, diesel fuel, gasoline, dielectric fluid, etc.;

• Construction of containment structures witl1 absorbent booms, and other absorbent materials, such as sand or dirt;

• Transferring spilled materiels into appropriare containers, such as drums or plastic bags using non-sparking shovels, pumps, or brooms; and

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H-26 Spill Prevention Plan ENSR IAECOM Cross Hudson Project February 2008

• Consideration of appropriate alternatives for large spills, sum as contracting a spill cleanup contractor.

7. If a spill is immediately hazardous (i.e., gasoline spill that poses a fire or explosion hazard), and cannot be handled by on-site personnel, or has entered the environment, the Cross Hudson representative will contact a spill response contractor.

8. The Cross Hudson representative will initiate other clean-up activities and monitoring, if required by applicable regulatory authorities.

9. The Cross Hudson representative will submit written reports to the required authorities, where applicable.

10. The Cross Hudson representative will update authorities with new information as it becomes available, if necessary.

11. The Cross Hudson representative will document spill response activities and maintain records of all spill notifications and responses on site.

Oil-eontaining debris resulting from oil releases to the environment (land or water) and contaminated spill response materials will be retained for characterization in the appropriate designated area pending disposal. Disposal will be performed in accordance with all applicable hazardous waste and/or solid waste regulations. If the debris is determined to be non-hazardous, it will be stored on site pending disposal at a facility licensed to accept such waste. If the waste is determined to be hazardous, it will be stored and disposed of with other hazardous waste generated at the site. Records, including manifests, documenting the date the contaminated debris were removed from the site and the location of ultimate disposal will be retained on site and/or submitted to authorities as necessary and in accordance with applicable regulatory requirements.

The Emergency Contact Ust (Table 1-1) contains contact information in case of any spill related emergency.

10.0 NOTIFICATIONS

This section details the response and notification procedures that are to be implemented in the event of an oil spill at the site that has contacted or threatens to contact environmental receptors sum as exposed soil, surface water, storm drains, or any entry point to the local sanitary sewerage system. When personnel have observed a release of oil of any volume, the Cross Hudson representative will be notified. The observer of the spill will communicate the location of the release, the material released, the volume of material released, and whether any amount has reached floor drains, storm drains, or exposed soil. The Cross Hudson representative will be responsible for determining what external notifications are required and for making all external notifications to appropriate regulatory agencies in the event of a spill or other emergency.

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H-27 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008

The procedures for notifications to the appropriate regulatory agencies in the event of a spill are described below.

10.1 Ora' Notifications

At a minimum, the Contractor shall notify the Cross Hudson representative in the event of an oil discharge, who will instruct personnel with regard to further notification(s). Phone numbers have been provided in the Emergency Contact List, located in Table 1-1.

1. Fire Department/Local Emergency Planning Council (LEPC) (if a fire or fume hazard is present or discharge migrates off of the construction site)

2. New York City Department of Environmental Protection (if discharge enters sewer system)

3. National Response center (if discharge causes a film or sheen upon water surface)

4. NYSDEC Oil and Chemical Spill Hotline (any reportable/non-incidental discharge)

5. Licensed Cleanup Contractor

Pursuant to 6 NYCRR 613.8 - Reporting Of Spills And Discharges, non-incidental discharges of petroleum must be reported to NY5DEC within two (2) hours of discovery by calling the NYSDEC Oil Spill telephone hotline.

Under 40 CFR 110.3, notification must be made to the National Response center when the facility discharges oil in harmful quantities into or upon naviqable waters of the state or adjoining shorelines. Harmful quantities include discharges of oil that:

• Violate applicable water quality standards;

• cause a film or sheen upon or discoloration of the water or adjoining shorelines; or

• cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

10,2 Written Notifications

Required written notifications will be made by the Cross Hudson representative to the proper authorities (within ten days for NYSDEC), and will contain the following information, as applicable:

• Facility name and location;

• Date, time, and place of discharge;

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H-28 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008

• The NYSDEC Spill Report Number;

• Names, addresses, and telephone numbers of all persons potentially responsible or liable for the discharge;

• The cause of the discharge, including a failure analysis of the system or subsystem in which the failure occurred, and the amountandtype of material released;

• Description of containment and removal operations, including costs of these operations; • The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements (including any third-party damages and costs of containment and removal operations); • Additional preventative measures taken or contemplated to minimize the possibility of recurrence; and

• Such other information as the authority may reasonably require pertinent to the SPP or discharge event (for example, site maps, flow diagrams, topographical maps, SPP). Should the NYSDEC require a written notification report, any such correspondence should be sent to:

Regional Spills Engineer NYSDEC - Region 2 Office 47-40 21 Street 290 Broadway U City, NY 11101

In addition, a written report shall be submitted to the US EPA Regional Administrator and a copy of said report will be submitted to NYSDEC whenever construction activities have:

• Discharged morethan 1,000 gallons of oil in a single discharge event; or • Discharged more than 42 gallons (1 barrel) of oil in each of two discharge events within any twelve-month period.

The report must be submitted within 60 days and shall contain the information required by 40 CFR 112.4(a). Information submitted to the Regional Administrator should be sent to:

Regional Administrator C/o ChiefEmergency Response US EPA, Region 2 290 Broadway New York, NY 10007-1866 Phone: (212) 637-5000

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H-29 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008

11.0 SUBSTANTIAL HARM

Non-transportation on-shore facilities that, due to their locations, could reasonably be expected to cause substantial harm to the environment by discharging oil into or on navigable waters or adjoining shorelines must prepare and implement a facility response plan in accordance with 40 CFR 112.20. Facilities that meet certain criteria are considered to pose substantial harm to the environment. A checklist of criteria for substantial harm is provided as part of the regulation and was used to determine that the construction of the Manhattan Segment does not meet the requirements for posing substantial harm to the environment. The Certification of the Applicability of the Substantial Harm Criteria is located in AppendiX C.

12.0 PLAN AMENDMENTS

12.1 plan Review

. Plan reviews are required as follows:

• At a minimum, once every five years from the date on which the plan is first approved;

• If the plan is shown to be deficient in controlling oil spills;

• To clarify the measures that were taken to remedy an oil spill, where the plan is not considered to be deficient in controlling the oil spill; and

• When there is a change in design, construction, operation, or maintenance that materially affects the potential to dischargeoil or pollutants into or upon waters of the state.

The plan must be updated as needed to include more effective prevention and control technologies if the technology has been field proven at the time of the review and will significantly reduce the likelihood of 'a discharge. Each review must be documented in the log provided in the front of this plan, or an equivalent form, whether or not amendments to the plan are required.

12.2 Professional Engineer (PEl certification

PE certification is required for technical amendments that require the application of good engineering practice. Non-technical changes (i.e., those that do not affect the oil storage operations at the facility) that do not require PE certification include:

• Changes to contact information (names, titles, and phone numbers);

• More stringent requirements for storm water discharges associated with NPDES rules that are not addressed by and do not impact the SPP;

16

H-30 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008

• Product changes if the new procluct is compatible with conditions in the existing tank and secondary containment; and • Other changes that do not materially change the potential to discharge oil.

13.0 ENGINEERING DEFICIENCIES

Provided that the Contractor operates in accordance with this SPP, there are no engineering defICiencies relative to 40 CFR 112. The Contractor must continue to ensure that the measures desaibed in this SPP (e.g., inspections, training, security, housekeeping, etc.) are implemented.

17

H-31 H-32 CROSS HUDSON PROJECT

SPILL PREVENTION PLAN

APPENDIX A

Sample Inspection and Reporting Forms and Spill Response Equipment

H-33 H-34 Appendix A Oil SlDrageArea I~

Allreferences to CDI1Iainer aremeantto indude alltanks and CDI1Iainers storing~ 55gallons ctoil.

Conduct inspe:lions 00 a monthly basis. If there is ro oil in a parti::lJ1ar cootainer, makea rdatiooI 00 the log. The date and time ctthe inspediol1 and the i I5pedor's narre at the top ctthe log priorto CDIlduding tre inspedi:Jn will also be noted. If rc deticiendes are noted, incflCale suchin the appropriate cell. Ifdeticielldes are disaNered, 1100! the deticiendes and record any CDrTedive adions taken or needed. Record the final resoIutkJn or outmme ctead1 CDrTedive action. Alldeticiendes must be 0011 eded as5OlJ1 aspossible.

use the foIk:7Ning guidelines for inspecting the CDI1Iainer syslBn, oompleting the inspedioo log, and taking CDrTedive adions.

1. InspOO: the area for adequalE housekeeping. If there is trash, dutter, spilled materials, or waste in the area, dean it up.

2. InspOO: the CDI1dition ctacassible p:lrtions ct CDI1Iainers. Ched< for signs ct release ctoil or llJilosioll. Releases ctoil may be evident: !7l' observation ctIquk:t in the secondaly CDI1Iainment syslBn, or rnoisUJre at the seams or other IocatioIIS 00 the oontainer. If tIlis is observed, ensure t!lat no additional oil is added. StEp; mustbe taken to empty the CDI1Iainer and oorred the pobIem. If any signs ctrust areobserved 00 the exteror ct a oontainer wall, 1100! the size and Ioc:atiCIl in the inspedioo log and have the oontainer repaired/repai1ted the next tirre the CDI1Iainer is erT1j:tied. In the meantime, oontinue to watl:h for any increase in size ctthe rust spot and anysigns ctrelease.

3. InspOO: acassible p:lrtions ct the area itnmetIiatBIySlJrrvunding the oilstlri1g axd:aineriIIId the $BODI7daJy mnlalnment syslBn to dellld signs ct release (i.e., wet spots, stains, eII:.). If signs ct a release areobserved, ensure t!latno ackfiticnal oil isadded to the CDI1Iainer. StEp; must be taken to empty the CDI1Iainer and oorred the pobIem. InspOO: the seCDIldary CDI1Iainment syslBn to ensure it is in good CDIldition (e.g., no cades or gaps in llJio~ dikes, no signs ct oonosion in steel dikes). In addition, the floors and walls should be examined for signs ctcades or deterioration. If deterioration is noted, the area should be repaired.

4. InspOO: all visible ancillary equipment. Ancillary equipment indudes piping, tittillQlS, pumps, valves, gauges, ell:. USEd to distribute, meter, or oontroIthe flowctoil or to view the IeYeI ctoil. InspOO: all visible p:lrtions ctthe andllary equipment Ched< for signs ctreleases (i.e., drips, llJilosioll, damage, missing or loose parts, eII:.). If these probIeIllS aredelEded, ensure t!lat no additional oil is transfened to the andllary equipment StEp;mustbe taken to oorred the pobIem.

5. If any items are noted in the log as deIicieJ rt, they must be doaJrrented and oorreded immediatEly. Desoibe rolieditleadionsin the space provided. If roore space is needed, Use the oomment se:::tiCI1 at the bottom ctthe table, wit!l a cross-refelellCe to the date and item number. If the intEgrity ctthe oontainer or CDI1Iainment strudure is oompromised, and/or if there is evidence cta release or potEntial release ctoil, the syslBn must be stlut down until the deficiency is oorreded, and re-inspeded prior to resuming operations.

6. EntEr the dare that conedive action _ axnp/etBd. If CDrTedive action cannct be oomplela:J 00 the sarre day as the inspedioo, indicatE the date t!lat it is anticipatEd to be oomplela:J, and, 0I"lCe oomplela:J, make a rdatiooI to oonfinn t!latit was oomplela:J andthe acllJal dalE ctoompletioo.

A ropy ctinspe:tion reoords mustbe kelX for at least tIlree years from the dalE ctthe inspedioo.

H-35 Appendix A Inspection Checklist DatI!: ------­ Time: _

InspedIlr"s Printed Name: _

InspeclDr'sSignalure:, _

ExteIior surfaces ci all tanks, pipes, valves, am other equipment must be dled

ContaIner Desaiptlon fJb hll I llif nl IsI'! 111 IIIi jlt.

, .

H-36 Appendix A Spill Response Equipment Inspection List

The site must be stocked wiltl spill response equipment (l.e., sorbent materials, pads, sausage booms, shovels, boots, gloves, coveralls, etc.) such tnat response personnel can reach any spill location wiltlin minutes.

Approximate Inventory On Hand It Item Comments Inventory PPE

Safety Gooo les TvvekSuits Neoorene Overboots Work Gloves Spill Control Equipment

Inert Absorbent Material Absorbent Pillows Absorbent Pads Absorbent Booms Spill Control Tools Spark resistant shovels Brooms Miscellaneous handtools Squeegees Traffic cones Barrier Tape Miscellaneous

Emotv Drums Over-pack Drums

Date Inspected

Name

H-37 Appendix A Spill Response Form Date: ------­ This document is to be used when making phone notification to an outside entity of a reportable oil spill in satisfaction of NYSDEC notification requirements (6 NYCRR 613.8). Complete form prior to making phone notification and retain as part of release file.

Name, telephone numberof caller, name of individual and agency notified (agency location)

Location of the oil spill or threat of oil spill

Date and time of the oil spill occurred; durationof the oil spill

Name and type of the oil released or threatened to be released

Approximate quantity of oil spilled or threatened to be spilled

Source of the oil spill

Brief description of the spill

Name, phone # of company contactperson at involved location

Name, phone # of owner/operator/senior manager of involved location

Measures already taken/ to be taken in response to the oil spill

Ust any other pertinent infonmation, which is relevant to assessing degree of hazard posed by the release of oil, induding but not limited to: precautions and evacuation recommendations, potential environment impact, indication of hazardous nature of the released material, etc.

H-38 CROSS HUDSON PROJECT

SPILL PREVENTION PLAN

APPENDIXB

Sample SPP Training Outline

H-39 H-40 AppendixB sample SPP Training Outline

Training Outline

The following topics will be discussed during SPP training: • Designated Person Accountable for Spill Prevention, Spill Prevention Procedures, and Spill Reporting Requirements; • Review History/cause of Known Spill Events at the Site; • Describe Recently Developed Precautionary Measures; • Describe Storage Tanks andTankOperations; • Describe Spill Containment/Control for Each Tank; • Describe TankTruck Unloading Procedures; • Describe Spill Containment/Control for TankTruckUnloading; • Describe Use and Location of Spill Control Equipment; • Describe Procedures for Draining/Pumping Oil from Containment Area; • Describe Sitesecurity Precautions; and • Additional Information Relevant to SPP.

H-41 H-42 CROSS HUDSON PROJECT

SPILL PREVENTION PLAN

APPENDlXC

Certification of the Applicability of the Snbstantial Harm Criteria

H-43 H-44 AppendixC Certification of the Applicability of the Substantial Harm Criteria (per40 CFR1.12.20) Facility Name: CHC Facility Address: 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes 0 No Ii!I 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for predpitation within any aboveground oil storage tankarea? Yes 0 No Ii!I 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III to this appendiX or a comparable formula') such that a discharge from the facility could cause injuryto fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA's "gUidance for Facility and Vessel Response Plans: Fish and Wildlife and sensitive Environments" (see AppendiX E to this part, section 10, for availability) and the applicable Area Contingency Plan. Yes 0 No Ii!I (capacity is < 1 million gallons) 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula') such that a discharge from the facility would shut down a public drinking waterintake'? Yes 0 No Il!I 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last5 years? Yes 0 No Ii!I

CERTIFICATION I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, andcomplete.

Signature Name (please type or print) ntle Date

J If I. comparable formula is used, documentation of the rehabiliry andanalytical soundness of the comparable fannula mustbe attached to this form. ~ Forthepurposesof40 CFRpart 112, publicdrinking water intakes areanalogous to publicwatersystemsas described at 40 CFR 143.2(c).

H-45 H-46 CROSS HUDSON PROJECT

SPILL PREVENTION PLAN

APPENDIXD

Tables

H-47 H-48 AppendixD Table 1-1 Emergency Contact List

Emergency Coonlinators

Office: 201-571-2570 Kiewit Construction Mobile: Pa er: City Agencies

NYC Rre Department (LEPC) 911 or (212) 62B-2900

NYC Department of Environmental Protection 311 or (212) 639-9675

NYC Department of Public Safety 311

NYC Police Department Switchboard 911 or (646) 610-5000 State Agencies

New Yorl< State DEC Oil Spill Hotline (24 hour) (BOO) 457-7362

New York State DEC Region 2 Office(Manhattan) (71B) 4B2-4900 New YorkState DEC Region 2 Spills Duty Desk (71B) 4B2-4651 Chemical Bulk Storage Help line (SIB) 402-9543

New YorkState Rre Marshall (SIB) 474-6746

Federal Agencies National Response center I Spill Hotline (BOO) 424-BB02 Alternative S ill Hotline 732 54B-B730 EPA Region 2 (212) 637-3000 Spill Response Contractors

Clean Harbors, Inc. (BOO) 645-B265 (24 hr) (BOO) 669-5740 or safety Kleen (Northeast), Inc. 71B 777-6700 Healthcare services Bellevue Hospital center (212) 562-4141 462 FirstAvenue Harlem Hospital center (212) 939-1000 506 Lenox Avenue Metropolitan Hospital center (212) 423-6262 1901 FirstAvenue

H-49 Appendix 0 Table 4-1 Oil Source Summary

Source Contents capacity secondary Containment, Engineering Most likely route of exposure (Gallons) Controls, and Pollution Prevention strategy In case of Spill Refueling will occurat the work location on top of Spills from construction equipment have the an impermeable surface. The refueling areas will potential to impact paved surfaces and be located a minimum of 50 feet from any exposed earth. waterbody. Spills that occurover exposed soils are not Spill response equipment will be located in expected to contactnaVigable waters designated and clearly marked areas throughout because spills wou Id permeate exposed soil. the construction site, facilitating quick access in All impacted soils would be removed from the eventof a spill. the site for proper disposal. Fuel Oil Hydraulic oil Stormwater pollution control measures, including Construction Spills that contact exposed groundwater will Lubricating Oil silt fencing and storm drain inlet protection, will be Equipment be remediated by pumping affected Transmission implemented at the construction site. Storm drain groundwaterinto containers or tank trucks AUid inlet protection will be installed on all potentially for proper disposal. Therefore, spills that affected storm drains. Other control measures impact groundwater are not expected to implemented at the site will providecontainment contactnavigable waters. in the eventof a spill.

Construction equipment is inspected on a weekly Dueto the implementation of stormwater basis, minimizing the potential for a spill. pollution control measures, including silt fencing and storm drain inlet protection, it is not expected that spills on paved surfaces will enter storm drainsand impact navigable waters.

T -') Source Contents Capacity Secondary Containment. Engineering Most likely route of exposure (Gallons) Controls, and Pollution Prevention Sb'ategy In Case of Spill USCG and USDOT procedures will be followed Spills from marine vessels may directly when refueling of equipment located aboard impact navigable waters. Presence of spill marinevessels is refueled. response equipment and implementation of spill control measures will minimize impacts. Spill response equipment will be located on marine Fuel Oil vessels facilitating quickaccess in the event of a Due to the Implementation of spill prevention Hydraulic oil spill from the vessel. Marine Vessels Lubricating 011 and control measures, it is not expected that spillsfrom equipment located aboard marine Transmission Spill response equipment will meet USCG and vessels will contact naVigable waters. Fluid USDOT requirements.

Marine equipment is Inspected on a weeklybasis, minimizing the potential for a spill.

Miscellaneous oil Paved surfaces and building structures serve as Spills from portable containers are not products and secondary containment (l.e., constructed with expected to contact naVigable watersdue to impervious floorsand away from exterior walls, waste oil stored Varies their location at the site, presence of spill throughout the drains, and doorways) for miscellaneous oil response equipment or use of spill site products stored insidethat are not located on spill containment systems. containment pallets or within bermed areas.

H-51 H-52 CROSS HUDSON PROJECT

SPILL PREVENTION PLAN

APPENDIXE

Site Plan Figure

H-53 H-54 Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT I

Cable Details

1-1 Construction Data of Submarine Cable

1-2 Cross-Section of Submarine Cable 1-3 MSDS for Cable Fluid

02:002J98_CCI2_04-B2311 I-I R_EMCP Hudson River SegITEDLdoc-2129108

Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT 1-1

Construction Data of the Submarine Cable

02:002398_CCI23)4-B2311 1-3 R_EMCP HudsonRiver Segmenldoc-2129108

Table 1 - 1 Constructional Data of Fluid-Filled Cable No. ltern Unit Specification I Oil passage (diameter) in (mm) Nom.O.n (18.0:!:1.0) 2 Galvanized steel spiral thickness mils (mm) Aoorox. 31.5 (0.8) Size sc.mm 2500 3 Copper conductor ShaDe . Cornoacted 6 sezrnental Outer diameter inch (mm) ADorox.2.56-(65.]) 4 Se;:;arator Taoes between seoments . Aoolied Binder tape thickness 5 Mils Approx. 10 in total ~(Stainless steel taoe intercalaled carbon black oaoer tape) Conductor screen thickness 6 Mils Approx, IS in total ICarbon black oaoer tanes and metalized oaner taoe) Inner kraft paper tape, approx. 19.7 mils (mm) 10.5) Insulation paper PPLP, approx. Min. ave. 551 7 thickness mils (mm) 748.0 (19.0) (14.0\ Minimum average Outer kraft paper tape, approx 177 mils (mm) 14.5) Insulation screen (Carbon black paper tape and metalized 8 Mils Approx. 16 in total naoer tape intercalated carbon black naner lane) 9 BindeflConner woven fabric tanO) mils Imm1 Anorox. 12 10.3) I Thickness mils (mm) Min. Ave. 15i74.0\ 10 Lead alloy sheath Outside diameter inch (rnrn) Aoorox. 4.49 (114) Reinforcement thickness (Fibrous tapes and slain less 11 Mils Approx, 43 in total lanes) 12 Return conductor total area !2 lavers of conner flat lane) (SQ.mm) Anorox. 2 310 13 Binder tape thickness (Rubber coated fabric taoe) mils (rnm) Aoorox. 2410.6) 14 Anti-corrosion jacket (Black Polyethylene) mils (mm) Min. Ave 177 (4.50) 15 OOtical fiber unit diameter mils (mrn) Aoorox. 157 (4.0\ 16 Binder TO;;;:- thickness Mils (rnm) Aonrox. 2010.5) 17 Beddina (aolvnroovlene varn) mils (mrn) Aoerox. 59 (1.5) 18 Galvanized steel wire armour diameter mils (mm) Nom. 315 (8.0\ 19 Servi~vnroovlene varn) mils Imml Anorox. 161 (4.1\ Performance Data Overall diameter inch!mm) Aoorox. 7.28 (185) Weioht Ibs/rtIk2/m\ Anorox. 70.6 nOS) Max. D.C. conductor resistance at 20·C ohmlkm 0.00732 Max. electrical capacitanceof insulation /LF/krn 0.37 Cable fluid volume of completed cable approx. Lr/krn 2,810 90 (Continuous) Maximum allowable conductor temperature "c 105 (Emergency over 1_':-., 6.0 (Static) Maximum allowable pressure kg/cm2 11.0 (Transient)

Minimum allowable bending radius mm 4,570 (180")

4 1-5

Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT 1-2

Cross-section of the Submarine Cable

02:002398_CC 12_04-B2311 1-7 R_EMCP Hudson RiYef Segm=olixx:-2n9AJ8

Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT 1-3

MSDS for Cable Fluid

02:002398_CC12_04-B2Jll 1-11 R EMCP Hudson River SelZnrnt.doc-2f29J08

EHV CABLE OIUlABl.dor:

MATERIAL SAFETY DATA SHEET'

Note: Read and understand Ualerial Safely Dale Sheet beIOns handling or dlsposing.ol·prod\Jl:l.

Issued date: 22 Mai'Ch 2006 M8D8 No, 44947 SECTION 1. CHEMicAL PRODUcT AND COMPANY IDENTIFICATION

COMPANY IDENTIFICATION NIPPON OIL CORPORATION. 3-12, Nishi Shlmbashll-chome, Mlnato-lcu, Tokyo, 105-8412 Japan EMERGENCY TELEPHONE NUMBER: +81-3-3502-9168 TELI9'HONE NUMBER FOR INFORMATION: +81-3-3602-1111' FAX NUMBER !'OR INFORMATION: +81-3-350U365 PRODUCT NAME: EHV CABLE OIL (LAB) PRODUCT USE: Cabls 011 sECTION 2. COMPOsiTION 'INFORMATION ON INGREDIENTs

COMPOSITION Comoooents Amoun!!%) Unear alkyl benzene 100

Hazardou' Information No OSHA expooure 11andard or TLV has been esblbllshed lor this malarial; SECTION 3. RAZARDS IDENTIFICAtiON

EMERGENCY OVERVIEW Werning c1atament Cautlon! Prolonged or repealed contact with skin may cause ilT1tation In some cases. P....,.tJ1lonal)' Meuu....: Avoid breathing vapor and mist K..,p container closed. Avoid contact 101111 8)'l1S. IIkJn. and clothing. Wach thoroughly after handling, Keep away from heal. Po16ntlal health elleet: Eyu: May CaUlS minor Irritation. Skin: May cause minimal skin In1taUon. Inhalation: Vapor or ml.~ In .-as 01permluibla concentr.tio..... or In unusually high,concantrations generated from .praylng. heaUng the malet1al, or .. lrom exposure in poorly ventilalBd areas or confined space•• may cause Irrllation 01 the nose end throat headache, nausea. and drawsl"""". Ingastlon: May caUSe abdominal discomfort. nausea, or dialTr.ea. Sansltizatlon propartlo.: Unknown Chronic properties: II prol,mgod expo....e occurs, nausea, ha.dache, dialThea, and physical discomfort Other ,-.m.ri(wi NoM

1-13 EHV CABLEOIULAB\.doc SECTioN 4. FIRST AID MEASUREs Eyes: Flush Invnedlal.ely with walltr for at least 15 mlnuteo. G.t immediate medk:ol attention. Skin: Wash with soap and wsw. Get medeal.atlention If irritation develops. LaunderconlBminatad clothing be€ore reuse. Inhalation: Remov. expooed person tofreoh air if adverse effects w. observed. Ingestion: 00 not make peraon vomit urile....directedto do SQ by medical personnel. Note to-p/1yllician: Treat symptomallcally. . . SECTioN 6, FIRE FIGHTING MEASURES Flash point (TypleaQ, "C 146 (PM) Aulolgnltlon tampL, "C NO! Determined. flammability limite: Not D.termlned. ~ngulah'l1lI media: CO•• dry chemical, or 108m. Sp.clal fire fightlng procedures: Recommend wearing sell-

Proc.duree In Case of Accidental R.I..... Breakage or Leakage: step the oouree of the leak or release. Clean up releases as soon aa poaaibl•• Contain liqUid to prevent further conlBmlnalion of SOIl, lUlface waler or groundwBter. Cllan up small spills using appropriate techniques such .s .or~t materials or pumping. Where fea81b1e and appropriate, remove conmmlneted 8011. Follow prescribed procedur•• r.... reporting end ,"pending to larger rel...... SEcllON 7. HARDONG AND STORAGE

Do not weld, heat or dnll container. R.place cap or bung. Emptied container sUIi contains hazardous material which may ignite with .xploslve v101erc. "healed sufflolenlly. Minimum f.eslbl. h.ndllng lamperel1ne ellould be malnllllned. Paneds of expos..." to high temperaluras she'*! be minimized. Water contamlnatlon should be OVold.cl. CAUTION: Donot us. pressure III amply drum or drum may rupture with explosive force. SECTION 8. EXPOSURE cONTROLS I PERSONAL PROTECTION

Eya Protection: Chemical type goggles or fac••h1e1d op~onal. Skin Protacllon: 'Avoid prolonllBd or frequentlyrepe.ted okIncontact by waaring Impervlouo protective clothing Includingglov•• R••pl..../)' Prot.ctlon: Wear. breathing m.sk. Ventilation: No speolel ventilation te u"uaIly necessary. However, If operating conditions create . high air borne conc.nndons of this rnalsnal, specl.1 vanUiadon may be needed. other clothing and Equipment: No .paclal doth/ng or equlprnentla usually necNllliry, Work pradlces, hygienic practices: No InformallonIs avaDable. Oth.r handling and storage requlremen1s: No Information Is avallabla. protactlvw meiJ5UreS dUring malntenanca ot contamlnatlMl eqUipment: NO Data Available.

1-14 EHV CABLE OIUlABl.doc SECTION O. PHYsicALAND CHEMICAl PROPERTIES Odor No odor Appearaooe Traneparan\-llquld Bolling polnt ·C No Data Available SDlubility .InsOluble In·water Density @15"C. g/cm' 0.861 Po.. point "C <-SO DMSO ExlrllCt mass % (lP 346) No Data Available sECTION 10.STABIUTYAND REAcTlVlN

StabilItY: Stable Conditions to·Avold': See the Handlingand atorage section lor lurttler details. incompatibility (materials to avoid): Acids. Oxidizing egants. Halogens and haloganated compounds. HaZlinloua Polymerization: Will not occur SEcTION 11. TOXiCOLOGICAL INFORMATION

Acute Oral: No DataAvailable: Believed \0 be greater lIlan 5 g/kg (ra~ PI1ICllcaIIy non-loxIc Dennel: No DataAvailable: Believed to be greater than 3 glkg (rabblQ Preotlcally non-loxic No Data Available: SEcTION 12.EcOLOGICAl INFORMATION

Biodegradation: Linear alkyl benzene Is mont biodegradable than branched elkyl benzene." Sturm Method (LInear dodecyl bonune) : Degradation (paosleveQ fOt 28 days." Environmental fate: This material II not expected 10I"etant any anvlronmental problems other than those assoclatad with oil aplill. SECTION 13. DispOSAl cONSIDERATIONS

Wa&te DI.posal Method: Place oonlaminated malarial. in disposable conllll"... end dispose of In a manner consistent with applicable regulations. Conlaotlocal environmental or health authalUn for approved disposal of this material. SECTION 14.TRANSPORT INFORMAtiON

The descrlptlon shown may notepply to all shipping slluationo.

DOT Proper Shipping Name: Not applicable. IMOO Proper ShippIng Nama: Not appllceble. ICAD Proper Shipping Name: Not applicable. TOG Proper Shipping Name: Not spplieabl•• NFPA Proper name: C1l1S81. UN Number. Not applicable.

1-15 EHV CABLE QILlLABl.doc SEel10N 15. REGULAtiON INFORMAtiON Tha U.S.TSCA lnventoly: All components 01this material or" on tha US TSCA Inventoly. The EC EINECS Inventoly: All """,ponenls of this malerlal_ Oll\he EC EINECS·lnvenlory. The CANADA DSL Inventory. All canponenls of tills malerial are on the DSLimrentory. Tha AUSTRAUA AI.es Inventory: All components of this malerlel 818 on \he AlCS Inventory. The KOREA.TCCL (manJory: All componants of this matar1a1 are on \118 TCCL Inventory. The PHIIJPPINE PICCS Inventory: All components ollhls malerial'are on \he PICCS Inventoly. SECTION 16.OTHER INfORMAtiON

None

References:

1. Handbook 01TOlClc and Heurdous Chemical' end Carcinogens [2nd ed.) 2. Regl&1ry anoxic Effects 01Chemical Substances (NIOSH. 1983) 3.12695 Chemical Prodl£1B.(The Chemical DeIly Co.. Lid. 1995) 4. Comparison of Methods for the Biodegraclablilly Evaluation of Soluble and Insoluble Organochemlcal&. Ecotoxlcol. Envlron. Salely 8, 275-279 (1984)

Maleriel ealely data aheels are provlded as relerence Information on the safe handling 01hazardous or hanmful . materials to companies using such meterials. When relerring to this data sheet, compen'.. should ramember !Ihet. they must taKe responslbQlly lor Implementing \he proper measures lor their own partfcular situations. TIls data sheells not e guarantee of salely.

1-16 Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT J

Marine Construction Equipment

J-1 Vessel Descriptions

J-2 Pre Lay Grapnel RunlBurial Assessment Survey J-3 Pipeline Protection and Stablisation Systems

02:OO2398_CCI2_04-B2311 J-l R_EMCP Hudson River Segnrnt.doc.V29108

Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT J-t

Vessel Descriptions

02:002398_CCI23l4-B231I J-3 R_EMCP Hudson River Se8~nt.doc-2/29108

Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT J-2

Pre Lay Grapnel RunlBurial Assessment Survey

02:OO2398_CCI23)4-B2Jll 1-1 R_EMCP HudsonRiver Segr

Confidential Trade Secret Critical Infrastructure

CROSS HUDSON PROJECT

ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN

ATTACHMENT J-3

Pipeline Protection and Stablisation Systems

02:002398_CCI23W-B231I 1-17 R_EMCPHudsonRiver Segmentdoc.2129iUS

~~.s: ~~ ~~ e ,~ Offshore/Onshore Solutions

SUBMAT

PIPELINE PROTECTION AND STABILISATION SYSTEMS

Submatis a trading name of SLP Precast South East Asia contact information; United Kingdomcontact information: Limited. Hamilton House, BatteryGreen Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502 548180 Loweston. Suffolk NR32 1DE Faseimile No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 FirstPoint Assessment No.10044028 Email: [email protected] Email: albert.russeU@sl~ng.com Website:www.slp-eng.com Website:WWIN.slp-eng.com OfunorelOnsnorE' Solutions

SUBMAT

Submat Bitumen Mattresses Submat Flexiform Concrete Mattresses Submat Pipeform Concrete Mattresses Submat Frond Flexiform Submat Brrumen Mattresses Concrete Mattresses Field Joint Coatings Impact Resistant Pre-cast Protective Covers Pipeline Crossing Supports Field Joint Coatings Special Projects incorporating Grout/ BallastBags Purpose-Built Pre-cast Structures River and Coastal Protection Mattresses SubmarFJexiform Grout/Ballast Bags Concrete Mattresses Technical/Design Services

Submat's range of services is aimed at meeting the special requirements associated with the installation of offshore oil and gas pipelines / structures and their related works. Whatsoever your requirements. Precast Pipefine Concrete Cover

4m x 1.5m x 450mm Mattress draped over a 20" pipe. Purpose-Built Pre-cast Concrete Structures

Submat is a trading name of SLP Precast South East Asia contact information: United Kingdom contact information: Limited, Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502 548180 Lowestoft, Suffolk NR32 1DE Fascimile No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 First Point Assessment No.1 0044028 Email: [email protected] Email: [email protected] Websile:www.slp-eng.com Website:www.slp-eng.com 2 SBM-DTS-016 REV 3 Page 1 of 1 otfshcreronsbcre Solutions

SUBMAT FLEXIFORM

Submat Flexiform is a low cost flexible concrete mattress developed as an addition to Submat's proven range of Submat bitumen mattresses which have been successfully utilised for protection of marine pipework for over three decades. Introduced at the beginning of 1991, Submat flexiform has itself established an impressive track record with various projects successfully completed on time, full details of which are available upon request. Flexlform consists of high strength concrete segments linked together with a network of high strength polypropylene ropes to form a continuous flexible concrete barrier. Flexiform by virtue of individually profiled concrete segments is able to provide a high degree of flexibility in two planes and as such allows for complete protection in most applications i.e. straightforward pipeline cover, at pipeline bends intersections on trenched I untrenched pipelines, for counter-action to seabed scouring or where there are pronounced undulations in the seabed profile. Flexiform can be installed with a simple quick release installation beam I frame which can be provided as an integral part of the order. Submat Flexiform is designed to provide a high quality, low cost solution for protection I stabilisation of subsea pipelines I structures and conforms to the requirements of 8S8110 'The Structural Use of Concrete'.

1. Completed 150mm thick mattress Oeing lifted from mould 2. Completed 300mm thic;k mattress beinglifted from mould. 3 150mmthick. mattresses storage area. 4. 300mmthickmattressas in storage area.

SBM-DTS-01 REV 4 Page 1 of 2 3 Offshore/Onshore Solutions

SUBMAT FLEXIFORM TECHNICAL DATA

STANDARD THICKNESSES

150mm, 300mm, 450mm

STANDARD DENSITY

2.4 Tonnes I Cubic Metre.

Lightweight and Heavy Density options are available from 1.6 - 3.6 Tonnes I Cubic Metre.

WEIGHTS (Standard Density Approx. Weights I m2 Tonnes)

Thickness In Air Submerged

150mm 0.275 0.152 300mm 0.510 0.279 450mm 0.770 0.430

STANDARD MATTRESS SIZES

Standard mould sizes are 10m x 3m, plan area. Mattresses may be manufactured in any size within mould dimensions subject to standard block sizes. Mattresses in excess of standard mould sizes may be manufactured to order.

STANDARD BLOCK SIZES (N.T.S)

MEASUREMENT IN MM

150mm THICKNESS 150

I I e194 < 394 >

300mm THICKNESS 300

! I e290 < 590 >

450mm THICKNESS 450 ) I I e440 < 690 LIFTING ARRANGEMENT

Integral lifting loops connected to quick release frame as illustrated on front of sheet.

CONCRETE DESIGN SPECIFICATION

G50 - 50N/mm' @ 26 days

Submat is a trading name of SLP Precast South East Asia contact information: United Kingdom contact information: Limited, Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (011502 546160 Lowestofl, Suffolk NR32 1DE Fascimile No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 First Point Assessment No.10044028 Email: [email protected] Email: [email protected] Website:www.slp-eng.com Website:www.slp-eng.com 4 SBM-DTS-01 REV 4 Page 2 of 2 Offshore/Onshore Solutions

SUBMAT BITUMEN MATTRESSES

2

Counteraction ro scouring the SUBMATBITUMEN MATTRESSESprogressively encourage sand build-up. Submat Bitumen Mattress the ocean's pipeline stabilisation and protection system. 1. Installation 2. Parfjallyembedded

3.Pennanentanchorage Developed and patented by Submat in 1971, the 3 Submat Bitumen Mattress is the original subsea pipeline protection mattress and is synonymous with the business of subsea pipeline protection. The Submat Bitumen Mattress has been deployed on numerous projects throughout the world up to the present time, and remains today a proven cost effective solution to many applications associated with subsea pipeline technology. The Submat Bitumen Mattress consists of a durable outer canvas envelope cJw integral lifting slings which is filled with a dense suitably re­ inforced bltu-mastic filler material. all of which Protection snd stabilisation against erosion .tland to sea trBnsltlon. combine to produce a flexible mattress that is suited for dealing with all pipeline support, stabilisation and protection requirements. Submat Bitumen Mattress in its solid form retains a fiexible nature even in the coldest operational conditions which enables the mattress to respond to ever changing seabed conditions which are partlcularty attributed to the problems of scour. The Subrnat Bitumen Mattress with its relatively void-less mass and size versatility is particularty successful in applications such as pipeline Stabilisation and separation padding for pipeline crossOV8n. crossovers Whereby support piers may be constructed with a minimal number of offshore lifts. The Submat Bjtumen Mattresses is installed with a simple quick release frame which can be supplied as an integral part of each order.

See reverse for Technical Data Prevention ofplpeliff and snakIng. 5 S8M-DTS-08 REV 2 Page 1 of 2 ottsrore/onsncre Solutions

SUBMAT BITUMEN MATTRESS TECHNICAL DATA

SIZE

The Submat Bitumen Mattress, can be manufactured to suit client specification generally up to 10m x 4m in plan area.

STANDARD DENSITY

Appro)(.. 2.2 Tonnes per cubic metre, may be varied from approx. 1.5 to 3.2 Tonnes per cubic metre.

MIX SPECIFICATION (Standard Density)

48% 14mm down graded stone / crushed rock 30.5% Sharp sand 1'.5% Limestone Filler 10% 200 penetration bitumen

ENVELOPE COVERS

The envelopes are manufactured from Duradon Extra or Regentex which are man made fibres.

Tensile strength in warp 2409N/50mm Tensile strength in weft 2628N/50mm

Tear strength in warp 400N Tear strength in weft 512N

LIFTING SLINGS

Each mattress is fitted with loomstate polyester lifting slings with a combined SWL of at least double the mattress weight in air.

Each sling has a break factor of 7 times the sling SWL, i.e. the combined sling break factor of a 10 Tonne mattress shall not be less than 140 Tonnes.

REINFORCEMENT MESH

Tensar Ar1 - Polyproplyene Weight 0.24kg/m3 Tensile strength Transverse 18kN/m Tensile strength Longitudinal 14kN/m

Submat is a trading name of SLP Precast South East Asia contact information: United Kingdom contact information: Limited, Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502 548180 Lowestoft, Suffolk NR32 1DE Fascimile No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 First Point Assessment No.1 0044028 Email: [email protected] Email: [email protected] Website:WNW.sJp-eng.com Website:WNW.slp-eng.com

6 SBM-DTS-08 REV 2 Page 2 of 2 Offshore/OnshoreSolutions

SUBMAT PIPEFORM

Submat Pipeform is a flexible concrete mattress strength polypropylene ropes which combine to designed as a stabilisation and protection offer a protective concrete blanket with a high system for all marine pipework, cables and degree of flexibility parallel to the protected umbilicals. pipeline. Submat Pipefonn has been developed as an Pipeform can be installed with a simple quick alternative to the multi-flexible type concrete release installation frame which can be mattress, where flexibility is specified by the provided as an integral part of an order. client or is primarily required as being parallel Plpeform can be manufactured in various sizes only to the axis of the pipeline. I thicknesses and confonns to the requirements Pipefonn is particularly suited for pipeline of BS 8110 'The Structural Use of Concrete'. stabilisation or pipeline cover. See reverse for Technical Data. Pipefonn consists of high strength reinforced concrete logs linked together with appropriate

, A demonstration of a 4m x 1.5m x 4.5m mattress being IIft&d and drappd over a 20" pipe. Approx. weight of example shown Is 5.1 tonnes.

SBM-DTS-04 REV 3 Page 1 of 2 7 OffshorelDI.ls.hore Sohrtiora

SUBMAT PIPEFORM TECHNICAL DATA

STANDARD THICKNESSES

150mm. 300mm, 450mm, 600mm

Other thicknesses may be manufactured to order.

STANDARD DENSITY

2.4 Tonnes I Cubic Metre.

lightweight and Heavy Density options are available from 1.8 - 3.6 Tonnes I Cubic Metre.

WEIGHTS (Standard Density) Approx. Weights Per Metre Length of log (Multiply x log length x No Logs for Mat weight)

Thickness In Air Submerged

150mm 0.054 0.031 300mm 0.180 0.104 450mm 0.379 0.219 600mm 0.648 0.372

STANDARD MAITRESS SIZES

Maximum log length = 10m Maximum proposed mattress width = 3m Width I length of mattress may be adjusted subject to adjustment of log length and No. of logs deployed

STANDARD BLOCK SIZES (N.T.S)

300mm 150mm Thickness e Thickness I I eII I 50 100 50 75 175 75 I I I I 200 325

450mm 600mm Thickness Thickness

eI I eI I 100 250 100 '50 300 150 I I I I 450 600 LIFTING ARRANGEMENT CONCRETE DESIGN SPECIFICATION Integral lifting loops connected to quick release frame C50· 50N/mtW @ 28 days Submat is a trading name of SLP Precasl South East Asia contact information: United Kingdom contact information: Limited, Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502 548180 Lowesloft, Suffolk NR32 1DE Fascimile No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 First Point Assessment No.10044028 Email: [email protected] Email: afben.russengpslp-enq.corn Website:www.sJp~ng.com webstte.www.sip-enp.com 8 SBM-DTS-04 REV 3 Page 2 of 2 OtfshoreJOns.hore Solutions

BLOWN GRANULAR MARINE MASTIC (PATENT NO. GB2372251)

Blown Granular Marine Mastic. Grade 02/5 is produced in accordance with our unique quality controlled process. The granular D2IS mastic has the appearance of loose. free flowing powdery granules. delivered in bulk bags ready for use. Bag size can be varied, but is typically around 1.2 to 1.3 tonnes.

ADVANTAGES OF USING BLOWN GRANULAR MASTIC

Free flowing characteristics More rapid melt down More convenient transport system (bulk bags) for improved logistics & offshore efficiency Less likely to clump and to be tacky Blown Granular Marine Mastic is designed to include a controlled moisture content to enhance the product's free flowing characteristics. A product, which is user friendly, easy to handle and melts rapidly, speeding up the joint sealing process.

RECOMMENDED STORAGE/POURING TEMPERATURES

Marine Mastic

Working Storage Temperature: 170°C· 210°C If due to operational requirements, there is a need to maintain the mastic at wor1

b) Pre-plan the storage time and jf in excess of those in a) the holding temperature should be reduced to 150°C or lower to be consistent with maintaining movement of the mastic in the Dope Kettle. c) When storage time is to exceed that in a) fresh material and or 85/25 Bitumen shall be added in sufficient quantity to maintain an acceptable flow characteristic. d) For extended storage times, lids on the Dope Kettle, where fitted, shall be closed to restrict exposure to the air which may accelerate hardening. e) After extended storage time at any temperature above melt, the mastic should be inspected and Pure Bitumen added when necessary to bring the mastic to an acceptable consistency.

Subrnat is a Irading name of SLP Precast South East Asia contact information: United Kingdom contact information: Limited. Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502 548180 Lowestoft, Suffolk NR32 1DE Faselmlle No: + (65) 6365 2569 Facsimile No: +44 (0) '502 548197 First Point Assessment No.10044028 Email: [email protected] Email: [email protected] webslte.www.slp-enp.corn Website:www.slp-eng.com 9 SBM-DTS-02 REV 5 Page 10f 2 Offshore/Onshore Solutions

BLOWN GRANULAR MARINE MASTIC (PATENT NO. GB2372251)

Blown Granular Marine Mastic in Bags waiting Hot Pouring of Granular Marine Mastic shipment

PHYSICAL PROPERTIES

02/8 Marine Mastic demonstrates the following key physical properties.

TEST METHOD SPECIFICATION TYPICAL MEAN VALUES Impact Resistance A1 - 557 o-c ~ Scm 18cm zs-c ~ 7cm 14cm Bending Resistance A1 - 557 OOe~2Ss >35 s zs-c ~ 30 s >60 s , Tensile Strength A1 - 557 DoC ~lS kg em­ 2 16.5 kg cm 25°C> 8 kg cm -2 8.6 kg crn? Compressive Strength A5TM D695 o-c ~ 650 psi 779 psi 1 (5mm min- ) 20°C ~ 220 psi 257 psi Elasticity Modulus A5TM D695 20°C ~ 1100 psi 10,546 psi (5mm min "") Density B5 594/598 Part 3 2,100 ± 50 kgm-3 2,158 kgm-3 Seawater Absorption 1Soe 1 Bar 0.040% 40 Bar - 0.094% 60 Bar 0.052% Electric Resistance B5903l2044 - >58.9 GO em

10 5BM-DT5-02 REV 5 Page 2 of 2 ~oms. ~\ Offshore/Onshore Solutions

IMPACT RESISTANT COVERS

Submat specialises in the design and manufacture of impact resistant concrete covers against given performance criteria. A standard semi-circular tunnel shape unit has been developed in addition to bespoke designed units for particular applications. Submat covers have been designed to accept loading up to 800 kj due to dropped objects and 45 kj due to trawl boards. , The shape of the covers are designed to , attract the least hydrodynamic loads and hence reduce scour. However, additional scour prevention systems (fronds) can easily be incorporated where necessary. Covers can be stacked for economical use of deck space.

../ f Impact resistant covers (trew/board and droppedobject)for expansion spools on the TOTAL DunbarProject.

Sizes can be designed to facilitate road transportation. Where larger units prohibit logistical movements, covers can be manufacture at a load out quay.

Impact resistant covers(traw/board and droppedobject) for expansionspoolson the TOTAL DunbarProject

Impact resistant covers (trew/board and droppedobject) fortee piece spoolson the Elf Frostpipe Projecf

Submatis a trading name of SLP Precast South East Asia contact information: United Kingdom contact information: Limited, Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No:+44 (0) 1502 548180 Lowestoft, Suffolk NR32 1DE Fascimile No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 FirstPoint Assessment No.10044028 Email: [email protected] Email: albert.russelljpslp-enq.com Website:www.slp-eng.com Websile:www.slp-eng.com 11 SBM-DTS-05 REV 2 Page 1 of 1 ~~.s: ~\ OffshorefOmhore Solutions

GROUT I BALLAST BAGS

The use of grout and ballast bags when dealing with support I packing operations for subsea pipelines and structures is common place with subsea operators. Although used independently, in many cases grout and ballast bags are installed to complement the primary method of protection l.e. mattresses I concrete covers etc. Submal supply grout and ballast bags to complement the Submat protection systems or as an independent item.

See reverse for Technical Data

GROUT BAGS

• J. TUBE SUPPORT

SUPPORT MA,TIRESSES

SAND BAGS

PROTECTIVE MATIRESSES

TRENCH FILL AT CROSSI"IG PRIOR TO PIPE LAY

Submat is a trading name of SLP Precast South East Asia contact information: United Kingdom contact information: Limited, Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502 548180 Lowestoft, Suffolk NR32 1DE Fascimile No: + (65) 6365 2569 Facsimile No: +44 (0) 1502548197 First Point Assessment No. '0044028 Email: [email protected] Email: [email protected] Websile:www.slp-eng.com Website:www.slp-eng.com 12 SBM-DTS-07 REV 2 Page 1 of 2 Ottshore/OI1~hore SoJutio~

TECHNICAL DATA

GROUT AND BALLAST BAGS CAN BE SUPPLIED TO SUIT INDIVIDUAL CUSTOMER REQUIREMENTS! SPECIFICATIONS AS INDICATED BELOW

Bags are available in sizes 10kg, 20kg, 30kg, 40kg etc.

Bags are provided in either polyprop or bio-degradable hessian.

Grout bags have an inner polythene damp-proof liner.

Grout mixes! constituents may be varied from neat OP.C. (Ordinary Portland Cement) to 1:1, 1:2, 1:3, 1:4 parts OP.C to kiln dry sand or as otherwise specified by the client.

Materials may be delivered on either pallets shrink - wrapped or in bulk bags of 1 tonne, 2 tonne etc.

I

SBM-DTS-07 REV 2 Page 2 of 2 13 OffshorelOnshore Solutions

DESIGN Examples of SLP's Design &Build prolects Submat personnel can provide all necessary design expertise including all computing and CAD facilities to prepare detailed designs, studies and reports for all aspects of offshore design, In house software has been developed to enable impact data and pipeline stability to be analysed, The development of concrete for use in a marine environment is well proven and the cost effectiveness of concrete as an alternative to traditional options has been demonstrated many times. Concrete is inherently a cheap material to produce and Pre-assembledpipespool bridge can be readily adapted. When properly designed the durability of concrete products in a marine environment out ~erlorms steel and requires no additional treatments such as cathodic protection or coatings. Used as gravity structures, no additional installation measures such as piling or ballasting are required to provide stability.

It is our policy to provide the client with a complete package by providing cost effective solutions which consider aspects such ---. as lift limitations, ease of positioning on the sea bed, transportation and optimised use of the installation vessel. Design aspects undertaken include: Flowline crossing bridge

Stability calculations to optimise mattress sizing for site specific environmental loading. Calculations and detailed design for trawlboard and dropped object resistance. Mattresses, covers, pipe supports, ramps, bridge crossings, anchor blocks etc. can all be designed to site specific requirements. Foundation design for pipe support systems. Scour prevention and remedial design studies. Impactresistant covers for expansion spools Innovative designs using reinforced and pre-stressed concrete for subsea applications. Hazard studies for impact criteria and risk from trawlboard effects. Research into the use of alternative concrete mix designs, e.g. lightweight and heavy weight aggregates, fibre reinforcement etc. Submathas a proven track record in designing against given perlormance criteria and is pleased to provide this service as part of an E.P.C contract Impactresistant Tee Piece cover or on a consultancy basis.

Submat is a trading name of SLP Precast South East Asia contact infonnation: United Kingdom contact information: Limited, Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502 548180 Lowestoft, SUffolk NR32 1DE Fescimue No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 First Point Assessment No.10044028 Emall: [email protected] Email: [email protected] Website:www.slp-eng.com Website:www.slp-eng.com 14 SBM-DTS-010 REV 2 Page 1 of 1 ~~s. ~~ It\t\\ OHshoreJOns.hore SOlutions

FROND FLEXIFORM CONCRETE MATTRESS

The "Frond Flexlform" Mattress, is a combined buoyant frond scour mat and flexible concrete mattress available in several standard variants, all have the same continuous and significantly overtappinq parallel lines of buoyant fibrillated polypropylene fronds attached to and aligned with, the lines of the concrete blocks.

No steel members (nor any other metals) are used in the blocks - this avoids dissimilar metal corrosion problems that have arisen in the offshore oil and gas industry from the use of slag in rock dumps. The Frond Line attachment points are moulded into the concrete base blocks.

FROND FLEXIFORM CONCRETE MATTRESS

The "Frond Flexlfonn" Mattress combines all the features of both a flexible concrete mattress and a buoyant frond scour control mat in one: and in particular it offers the following benefits: »installation is simple and swift, and it provides both instant protection and immediate hold down;

~ the creation of long term fibre reinforced, consolidated and vibration compacted sediment bank build up over the mattress SUbstantially adds to the degree of protection afforded and provides an exceptional reduction in scour potential close to structures:

»it provides scour protection for an area somewhat greater than the actual area covered by the mattress:

).- the individually profiled concrete segments provide a high degree of flexibility in two planes and allow for a complete protection of subsea structures and pipelines and offer a linked flexible foundation to ensure that load is spread evenly over an area; and

}.> the fronds prevent edge scour and also halt internecine block (or rock) scour, this eliminates any requirement for the use of geotextile filter screens under a Frond Flexiform mattress.

The submerged weight of the mattress on first installation will increase as the scour control system creates a fibre­ reinforced bank over the base mattress. The rate of build up and size of such bank vanes from site to site.

The build up of the material bank within the Frond Flexiform mattress is non-linear. The 1.25m high fronds create the greatest viscous drag when first deployed and the initial 200mm to 300mm of mat/mattress inf\ll occurs quickly in normal tidal conditions given the sort of sediment sizes at most offshore sites. As the material bank forms, the exposed frond length is reduced, the mat creates less viscous drag and the rate of formation of the material bank slows until a steady state is reached.

The sediment bank created is considerably more stable and more dense than the natural surrounding seabed: many surveys have conflrmed that it is considerably consolidated by the vibratory movement ot fronds during the sedimentary period and once in place it is permanently reinforced by the frond material.

Any sediment bank so formed extends out from the frond area to cover the sides of the base mattress extending out in descending curve to seabed level for a distance slightly greater that the height of the formed bank - the final shape of such a "curve" depends upon the coefficient of friction of the seabed particles.

SBM-DTS-031 Rev 2 Page 1 013 15 ~~s. ~~ /t,,~ Offshore/Onshore Solutions

FROND FLEXIFORM CONCRETE MATTRESS

SEDIMENT BANK PROJECTION

For offshore sites after some 20 to 45 days a significant. compacted and solid sediment bed will be in place and a height of not less than 450mm is normal: the final height of bank with a frond height of 1,250mm should should safely exceed 900mm in height after some 40 to 75 days. The formation of such a sediment bank over the Mattress provides submerged weigh or "held down". A typical SUbmerged weight of sand particles is 819.5kglm3, but the range is large thus the submerged weight of the fibre reinforced material bank can vary. For a 5.0m x 3.0m Frond area this should be:

• after 20 days: in the range 6.67 tonnes to 5.5 tonnes - this is additional to the base mattress' concrete block weight (with 150mm base blocks = 2.28l submerged weight and with 300mm base blocks =4.18t submerged weight).

• after 40 to 75 days: in the range 15.0 tonnes 11.08 tonnes + base mattress' concrete block submerged weight. BUOYANT FROND MATERIAL UV stabilised Polypropylene. Fully tested" Chemically Resistant". Specific gravity 0.908 and 0.92. Full fibrillated and with profiled film. FROND LENGTH & ATIACHMENT Buoyant Fronds are attached to Mattress in successive continuous rows providing substantial and unbroken overlap of fronds to those in the neighbouring rows. Frond clumps are NEVER used. Frond Length (height when deployed) of the lines of buoyant frond material is 1250mm. In riverine (and other special situations) lesser frond heights allied to a proportionate increase in frond density (spacing) in the frond rows may be used. A "Safe Net" frond release is provided for diver and ROV safety. STANDARD BLOCK THICKNESS 150mm, 300mm, and 450mm. STANDARD BLOCK DENSITY 2.4 Tonnes / Cubic Metre. Lightweight and Heavy Density options are also available from

1.8 - 3.6 Tonnes 1m3•

WEIGHTS (STANDARD DENSITY)

Approximately Weight I m' - at Installation

Thickness In Air Submerged (Tonnes) (Tonnes) (Tonnes)

150mm block 0.275 0.152 300mm block 0.510 0.279 450mm block 0.770 0.430

SBM-DTS-031 Rev 2 Page 2 of 3 16 Offshore/Onshore Solutions

FROND FLEXIFORM CONCRETE MATIRESS TECHNICAL DATA

TOTAL SUBMERGED WEIGHT The submerged weight will increase due to the material bank formed by the fronds: the weight of the bank varies according to the seabed composition. A typical SUbmergedweight of sand particles is 819.Skg I rna. but the range is large thus the submerged weight of the fibre reinforced material bank can vary. For a 6m x 4m mattress this should be in the range is large thus the submerged weight of the fibre reinforced material bank can vary. For a 6m x 4m mattress this should be in the range 23.9 tonnes to 19.9 tonnes • this is additional to the concrete weight which with a 150mm thick mattress at standard density would be 3.7 tonnes giving a total submerged hold down of 27.6 to 23.6 tonnes.

STANDARD MATIRESS SIZES Standard mould sizes are 10m x Sm in plan area. Mattress may be manufactured in any size within mould dimensions subject to standard block sizes. For pipeline ovenav either 4m or 5m width by 2, 3, 4, 6 or 10m length is preferred to provide cover 2 to 2'Xrm either side of the pipeline as well as over & along the line in a single installation. Mattresses in excess of standard mould sizes may be manufactured to order.

STANDARDBLOCK SIZES (N.T.S.) MEASUREMENT IN MM

150mm THICKNESS 1< ) e194 394

300mm THICKNESS ) I< I e290 590

450mm THICKNESS ) I I e440 < 890 CONCRETE DESIGN SPECIFICATION CSO-SON I mm3@28days. Conforms 10the requirements of BS8110: The Structural Use of Concrete ADDITIONAL GROUND ANCHORS Additional 1 tonne ground anchors certified by ABS and lloyd's may be attached at corners or edges to provide the additional edge hold down to increase protection capability (e.g. against trawling).

LIFTING ARRANGEMENT Integral lifting loops connected to quick release frame.

Submat is a trading name of SLP Precast South East Asia contact information: United Kingdom contact information: Limited, Hamilton House, Battery Green Road. Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502548180 Lowestoft. Suffolk NR32 1 DE Pascimiie No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 First Point Assessment NO.1 0044028 Email: [email protected] Email: [email protected] Website:www.slp-eng.com Website:www.sJp-eng.com 17 SBM-DTS-031 Rev 2 Paqe 3 of 3 SBM-DTS-04 1 Page 1 of 2

Offshore/Onshore Solutions

SUBSEA TECHNOLOGY SOLUTIONS THROUGH EXPERIENCE, EXPERTISE, QUALITY AND INNOVATION MID WATER ARCHES, GRAVITY BASES AND TETHER BASES

SLP has a wealth of experience in the design and build of offshore platforms and subsea structures. SLP has harnessed that experience to add to its portfolio the design and build of Mid Water Arch, Gravity Bases and Subsea Tether Systems. In conjunction with our partners Keppel, SLP can offer an experienced design team based in London with the ability to fabricate in various locations: Fabrication Destination Lowestoft UK & Europe Singapore Far East & Australia Brownsville, Texas Gulf of Mexico & Brazil

Flexible Riser Guide 18 Experience Expertise Quality Innovation SBM-DTS-041 Page 2 of 2

Ofh,hore!OnshOre Solutton~

MID WATER ARCHES, GRAVITY BASES AND TETHER BASES

Mid Water Arch Flexible Riser Guide

Our strongly client orientated approach ensures that projects are executed as efficiently as possible and our world wide fabrication capability ensures that the client gets what they at the most economic rate. Co-ordination between SLP the client and the installation company is vital to achieve the most economic design which SLP will tailor to match not only the riser and umbilical loading but also methods of the installation contractor. Submat is independently certified to ISO 9001 :2000.

Subrnat is a trading name of SLP Precast South East Asia contact information: United Kingdom contact information: limited. Hamilton House, Battery Green Road, Telephone No: + (65) 9753 0163 Telephone No: +44 (0) 1502 548180 Loweston. Suffolk NR32 1DE Fascimile No: + (65) 6365 2569 Facsimile No: +44 (0) 1502 548197 First Point Assessment NO.10044028 Email:[email protected] Email:[email protected] website.www.slp-enq.com Website:www.slp-eng.com Experience Expertise Quality Innovation 19