SUMMARY OF PRE-CROSSING CONSTRUCTION PLANNING PROCESS

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1 SUMMARY OF PRE-CROSSING CONSTRUCTION PLANNING PROCESS I. Introduction As requested by the New York State Department of Environmental Conservation ( DEC ) during a October 21, 2016 meeting with National Fuel Gas Supply Corporation and Empire Pipeline, Inc. (collectively, National Fuel ), National Fuel provides this summary of the process it will employ in advance of the construction of each stream crossing on the Northern Access Project ( Project ). Of note, National Fuel has used the process below to successfully cross hundreds of streams within the State of New York and the Commonwealth of Pennsylvania over a span of several decades. As such, the process below is tried and true, is protective of water quality, and, in turn, ensures that National Fuel s stream crossings, including those on the Project, are in compliance with New York State water quality standards and applicable permits. Additionally, National Fuel attaches stream-specific drawings for each of the streams crossed by the Project, each of which include, among other things, the method of stream crossing (such as dam and pump, multi-flume, HDD), crossing depth (including any extra depth required from the Vertical Adjustment Potential study), and applicable ESCAMP BMPs, and depict the pipeline route, pipeline right-of-way, and temporary work space. II. Stream Crossing Pre Construction Meeting Generally, two days prior to the construction of each stream crossing, National Fuel holds a planning meeting (the Planning Meeting ) at the location of the subject stream crossing site with the intent of optimizing the sequencing of necessary construction activities and determining the location of necessary support materials and equipment, as described below. At a minimum, National Fuel requires the following parties to attend the planning meeting: the contractor's Tie-in Crew Foreman, the contractor's Environmental Crew Foreman, National Fuel s Craft Inspector and National Fuel s Environmental Inspector ( EI ). s that are invited and encouraged to attend are: the Federal Energy Regulatory Commission ( FERC ) Environmental Compliance Monitor, the Project's Chief Environmental Inspector, National Fuel s Project Environmental Manager, National Fuel s Construction Manager, and the contractor's Field Construction Superintendent. At each Planning Meeting, items that are discussed and agreed upon are dependent on safety concerns, the planned method of crossing, current stream conditions, the anticipated weather forecast and the topography/profile associated with the stream crossing. National Fuel has developed a checklist, a copy of which is attached, which outlines various issues to be discussed during the planning meeting (to the extent applicable for each stream), many of which are listed below: 1

2 The EI is responsible for ensuring that the stream crossing permit conditions are reviewed, understood, and that the permit is on site. The Spill Prevention & Response Procedures (SPRP) plan is to be on site with adequate spill kit(s) and absorbent material; The estimated start time and timeframe for completing the stream crossing are determined, followed by a discussion of the site-specific limits of disturbance (LOD) including any extra work spaces; The stream trench spoil setback distance from the edge of stream will be located, including the placement of upland ditch spoil piles; Emphasis of the hazardous material setback distance pertaining to equipment refueling and overnight parking (cannot be within the 100 feet of the stream unless approved by the EI); The type of Erosion Control Devices (ECDs) to be employed and the locations of each are determined. These include ECD's necessary to protect and contain spoil piles, slope breaker(s) and trench breakers, on both sides of the stream, based on the topography, the location and type of ECD to be used for trench water discharge filtering and their proximity to sensitive resources, and the anticipated direction of discharge flow, quality of vegetation, and topography. There is also discussion to reiterate that special care must be taken when locating this discharge point and ensuring that adequate hose is on site to reach from the trench pump to the discharge ECD(s); If not already installed from previous operations, the temporary bridge crossing type and location is determined and if any additional earth work and protective ECD's are needed for the installation. The prefabricated stream crossing pipe section location is established for easy transport to the excavated trench; The upstream and downstream dam locations (including the quantity of support materials for each location); Verification that all pumps are in working order, the locations of the pumps and their secondary containment, the location(s) of standby pump(s), and verification that hoses onsite are long enough to support the planned pump around; The type of pump around intake/discharge equipment needed, and the in-stream location of each; 2

3 The location for materials, such as culvert(s) and sandbags, in the event that there is a necessity to switch from a dam and pump to an alternative flumed crossing method 1 ; The location of fire extinguishers, and the availability of light plants; Personnel are reminded that restoration of the stream crossing is to be started immediately after backfill; Finalization of the type of restoration materials (e.g. seed, ECDs), and also when and where these materials will be needed on site; and Reiteration that the stream crossing should not be started unless there is adequate time to construct the crossing, the current stream levels are manageable, all the critical materials and equipment are on-site and all equipment is functional. 1 The Dam and Pump and Dam and Flume crossing methods afford equivalent protection to the waterbody. Use of one technique versus the other can be impacted by the shape and size of the stream bed, stream flow, stream bottom substrate, height of banks, presence of consolidated rock, and other factors. 3

4 Stream Crossing Pre-Construction Planning Sheet Stream Crossing Width: Stream Name: Stream Designation: Project/Spread No.: Start Date: Time: Report End No.: Time: ER #: Centerline Station or MP: Crossing Type: Dam & Pump Flume Depth of Cover (VAP) Documents Required For Stream Crossing "including, but not limited to, the following" Stream Permit(s) SPRP Plan Documents Onsite Verified By Comments Location of Nearest Medical Center/Phone Number Materials Required For Stream Crossing "including, but not limited to, the following" Material Onsite Verified By Comments Dam Materials Trench Breaker Material Compost Filter Sock (CFS) Silt Fence (SF) Straw Bales Wooden Stakes/Flagging Geotextile Filter Bags Seed/Mulch Erosion Control Blankets (ECBs) *Flume Pipe(s)/Sand Bags Page 1 of 2

5 Equipment Required For Stream Crossing "including, but not limited to, the following" Equipment Onsite Verified By Comments Excavator(s) Dozer(s) Spill Kit(s) Trench De-watering Pump(s) Stream Diversion Pump(s) Backup Stream Diversion Pump(s) Pump Intake & Discharge Hose(s) Pump Containment Structure(s) Fire Extinguishers Light Plants (optional) Knowledge of Environmental Compliance *Flume Pipe(s) of sufficient size to convey stream flow must be onsite at all times during a dam & pump crossing. ** Permit Documents Must Be On Site At All Times** Foreman: EI: Craft Inspector: Chief Inspector: Const. Manager: Page 2 of 2