Filed: 2011-06-09

Niagara Gas Transmission Limited

St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 1
Page 1 of 1

NATIONAL ENERGY BOARD INFORMATION REQUEST 1.1

Land Matters and Consultation

1.1 Land Acquisition Process

Reference: i. Filing A1Y7W9 – Niagara Gas Application, Background-Lands:

Paragraph 32, Adobe page 8 of 34; and, Section 8 Lands
Information: Adobe pages 33-34 of 34.
ii. Filing A1Y7Y0 – Niagara Gas Application, Appendix H

Preamble: In reference i), Niagara Gas indicates that the proposed new
facilities will fall under land agreement arrangements already in
place and that no new easements will be required. Niagara Gas
goes on to say that temporary work space will be required on
private property on both sides of the crossing. Niagara Gas
states that it “has, or will acquire, all necessary land rights for
construction of the proposed facilities”.

Reference ii) contains a sample copy of an agreement for

temporary work space.

Niagara Gas has not indicated in its application whether its lands
acquisition process for any required lands, including temporary
work space, will comply with the NEB Act.

Request: Please confirm whether the land acquisition process for any
required lands, including temporary workspace, will comply with
sections 86 and 87 of the NEB Act.

RESPONSE

Niagara Gas will comply with section 86 and 87 of the NEB Act with respect to its land
acquisition process for the project.
 Filed: 2011-06-09
Niagara Gas Transmission Limited
St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 2
Page 1 of 3
Plus Attachment

NATIONAL ENERGY BOARD INFORMATION REQUEST 1.2

Land Matters and Consultation

1.2 Consultation with nearby residents regarding horizontal directional drilling

for the project

Reference: i. Filing A1Z1J3 – Niagara Gas Application; Appendix G

Environmental and Socio-Economic Report, Sec. 3.2.7 Liaison,
3.2.8 Public Open Houses and 3.2.9 Implementation of
Consultation Program Outcomes Adobe pages 32-36 of 62 and
Table 6-1 Adobe pages 49-50 of 62
ii. Filing A1Y7W9 – Niagara Gas Application, Appendix H, Adobe
pages 15-16 of 34
iii. Filing A1Y7X6 – Niagara Gas Application, Appendix E2
Temporary Workspace Drawings

Preamble: In reference i), Niagara Gas indicates that no feedback has been
received by the Company in response to published
announcements or information notices mailed to local residents
about the Project, including any potential concerns regarding
noise associated with the proposed horizontal directional drilling
(HDD).

Reference ii) states that within the city of Cornwall “… the nearest
residential area is located … approximately 20 metres from the
temporary work space boundary.” Reference ii) further states
that, on Cornwall Island, “The nearest residences are directly
adjacent to the temporary work space boundary.” Reference iii)
shows buildings in proximity to the HDD site and the temporary
work space.

Niagara Gas has not provided a record of its consultation

activities with residents whose dwellings are located adjacent to
the proposed construction and who may be affected by the
Project, including any concerns that may have been raised
regarding the proposed HDD.
 Filed: 2011-06-09
Niagara Gas Transmission Limited
St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 2
Page 2 of 3
Plus Attachment

Request: Please provide a record of Niagara Gas’ consultation activities

undertaken with potentially affected nearby residents including but
not limited to:
a. The resident/owner consulted, date for each contact and
method of contact (for example telephone, personal meeting,
email, letter);
b. a description or copies of any information provided to
residents, including any information pertaining to noise
associated with the proposed HDD;
c. A summary of any issues or concerns that were identified,
including any concerns regarding noise associated with the
proposed HDD;
d. The steps that Niagara Gas has taken or will take to address
any concerns raised; or
e. An explanation of why any steps were not taken to address
concerns raised.

RESPONSE

a. The environmental assessment conducted by Franz Environmental involved a

comprehensive public consultation component. A Notice of Public Information
Session (“PIS”) was published in the local newspaper (Cornwall Standard
Freeholder, Mohawk Times and Seaway Times) to provide notification of the PIS to
be held in both Cornwall, ON and on Cornwall Island. The Notice of Public
Information Session was also circulated to approximately 1600 local residences and
businesses through the Canada Post mail system. Information about the PIS was
communicated through radio announcements on Cornwall Island. The PIS was held
on February 16 and 17, 2011 in Cornwall, ON and Cornwall Island, respectively. It
was attended by representatives from Niagara Gas, Franz Environmental and the
MCA (on Cornwall Island) to provide information about the project and answer any
questions or issues raised by attendees.

b. A copy of the Notice of Public Information Session is attached and can also be found
in the Environmental and Socio-Economic Assessment Report and external website.
Information pertaining to noise can be found on slide 3 of the Public Information
Session panels.
 Filed: 2011-06-09
Niagara Gas Transmission Limited
St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 2
Page 3 of 3
Plus Attachment

c. No significant issues or concerns were raised through the public consultation

process. A record of the process can be found in section 3.2.8.2 of the
Environmental and Socio-Economic Assessment Report. One nearby resident
inquired about noise levels during the PIS held in Cornwall, ON. The HDD
contractor will be installing a sound panel barrier wall system between the HDD
activities and residents to minimize any noise resulting from the work activities.

d. The HDD contractor will be installing a sound panel barrier wall system at both the
Cornwall and Cornwall Island work sites, between the work area and nearby
residents to minimize the propagation of any construction related noise. The sound
panel barrier wall system consists of approximately 25-foot long by 4-foot wide rolls
of 4-inch thick Quilted Fiberglass Absorbers (“QFAs”) affixed from a 3/8” cable line
spanning between support posts either driven into the ground or supported on steel
road plates every 20-feet. The QFAs are manufactured by “Sound Seal” specifically
to absorb noise and are also fire-proof. This system has been successfully used by
the contractor (Michels Directional Crossings / Michels Canada) on many projects in
urban environments. Niagara Gas will also abide by municipal noise bylaws and
conduct work activities only between 7 a.m. and 7 p.m. However, during the critical
pull-back stage of the drilling operation, 24-hour a day work may be required. In
addition, all construction equipment will be properly maintained and equipped with
mufflers.

e. Not applicable.
 Niagara Gas Information Request 1.2 - Attachment

NOTICE OF PUBLIC INFORMATION SESSIONS

ST. LAWRENCE RIVER PIPELINE CROSSING REPLACEMENT
CORNWALL, ONTARIO
NIAGARA GAS TRANSMISSION LTD.

Niagara Gas Transmission Ltd. (NGTL), a wholly  

owned subsidiary of Enbridge Inc. is seeking
approval from the National Energy Board (NEB)
to construct a new pipeline crossing of the St.
Lawrence River (North Channel). The Federal
Bridge Corporation Ltd. (FBCL) intends to replace
the existing North Channel Bridge with a new low
level bridge and then demolish it. As the current
pipeline crossing is mounted on the North
Channel Bridge, a new pipeline crossing is also
required. NGTL intends to replace the 12 inch
diameter bridge-mounted pipeline with a 12 inch
diameter subsurface pipeline beneath the North
Channel. NGTL will file an application with the
NEB under Section 58 on the National Energy
Board Act in accordance with the requirements of
the NEB Filing Manual.

Approximately 800 linear metres of 12 inch

diameter pipe will be installed using horizontal
directional drilling (HDD) entering the ground at
the City of Cornwall and exiting the ground on
Kawehnó:ke (Cornwall Island).

FRANZ Environmental Inc. (FRANZ) has been retained to prepare an Environmental Assessment of the proposed
pipeline route. The study area boundary for this project is indicated by the dotted line. At this Public Information
Session, representatives from FRANZ and N G T L will be available to explain the project and answer questions
regarding the route selection process, the alignment, t h e rationale/requirement for the p i p e l i n e c r o s s i n g ,
construction procedures and specific environmental protection and mitigation measures.

Public Information Sessions regarding the proposed project are scheduled at:

Ramada Inn and Conference Centre Tri-District Elders Center

805 Brookdale Avenue, Cornwall, Ontario Kawehnó:ke, Akwesasne
Wednesday, February 16, 2011 Thursday, February 17, 2011
5:00 to 8:00 pm 5:00 to 8:00 pm

Comments and information regarding this project are being collected to assist the project team in meeting the
requirements of the National Energy Board Act. The report will become part of evidence to be filed with the NEB, as part
of the Section 58 application. These comments will be maintained for reference throughout the project and will become
part of the public record. Under the Freedom of Information and Protection of Privacy Act and the Environmental
Assessment Act, unless otherwise stated in the submission, any personal information such as name, address, telephone
number and property location included in a submission will become part of the public record files for this matter and will be
released, if requested, to any person.

Anyone having an interest in this study is encouraged to contact:

Mr. Edwin Makkinga Mr. Mike Grinnell, P.Eng. Mr. Scott Peters
Manager, Environment Project Manager Environmental Assessment Officer
Enbridge Gas Distribution Inc. Franz Environmental Inc. Mohawk Council of Akwesasne
500 Consumers Road 329 Churchill Avenue, Suite 200 101 Tewesateni Road
North York, ON M2J 1P8 Ottawa, ON K1Z 5B8 Kawehnó:ke, Akwesasne K6H 5R7
T: (416) 495-6789 T: (613) 721-0555, Ext. 236 T: (613) 936-1548
F : (416) 495-5523 F:(613) 721-0029 F: (613) 938-6760
edwin.makkinga@enbridge.com mgrinnell@franzenvironmental.com scott.peters@akwesasne.ca

This Notice first issued on February 5, 2011.

 Filed: 2011-06-09
Niagara Gas Transmission Limited
St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 3
Page 1 of 1

NATIONAL ENERGY BOARD INFORMATION REQUEST 1.3

Emergency Response Matters

1.3 Manuals

Reference: i. Filing A1Y7W8 – Niagara Gas Application cover letter

ii. Onshore Pipeline Regulations, 1999 (OPR-99), section 32

Preamble: Reference i) indicates that Niagara Gas is planning to construct

an approximately 800 metres section of replacement pipeline via
horizontal directional drilling for a portion of the Cornwall Pipeline
currently located on the North Channel Bridge of the Three
Nations Bridgeway originating in Cornwall, Ontario.

Reference ii) requires companies to ensure applicable emergency

procedures are developed and current, and are filed with the
Board.

An Emergency Response Manual review was conducted by the

NEB staff. The review had findings that concluded that it did not
meet the NEB expectations. On March 18, 2011 NEB staff,
contacted the Project Manager of Integrity from the operator of
the pipeline, Enbridge Gas Distribution Inc. to discuss the manual
in question. A verbal commitment was agreed upon to provide
new manuals to the Board to replace the deficient manual.

Request: Please file 3 hard copies of the latest version of the Emergency
Response Manual with the NEB for review.

RESPONSE

Enbridge Gas Distribution Inc. is in the process of updating the applicable Emergency
Response Manual, and expects to file the updated document with the Board on
June 13, 2011.
 Filed: 2011-06-09
Niagara Gas Transmission Limited
St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 4
Page 1 of 2
Plus Attachment

NATIONAL ENERGY BOARD INFORMATION REQUEST 1.4

Engineering Matters

1.4 Pipe Stress

Reference: i. Filing A1Y7W9 – Niagara Gas Application, Section 6.1.4 Pipe

Stress Compliance
ii. CSA Z662-07 Clause 4.2.1.2
iii. CSA Z662-07 Clause 4.22 d)

Preamble: In reference i), Table 6.3 shows the stress calculations for a
restrained pipe. It includes the stress resulting from the internal
pressure during the operation at the maximum operating pressure
(MOP), longitudinal stress from the thermal expansion and the
combined stress.

Reference ii) states that the effect of external pressures and

loading on the pipe during installation and operation shall be
accounted for using good engineering practice. The pipe wall
thickness selected shall provide adequate strength to prevent
excessive deformation and collapse, taking into consideration
mechanical properties, wall thickness tolerances, ovality, bending
stresses, and external reactions (see clauses 4.6 to 4.10).

Reference iii) states that pipelines may be installed by directional

drilling provided that, for steel pipe, longitudinal stresses during
installation do not exceed the specified minimum yield strength
(SMYS) of the pipe.

The application provides the stress values for a normal straight

pipe but does not provided stress values for the bending stress
caused by the shape of the horizontal directional drilling (HDD)
path, nor does it provides stress values involved during the
installation.

Request: Please provide the following:

 Filed: 2011-06-09
Niagara Gas Transmission Limited
St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 4
Page 2 of 2
Plus Attachment

a. A complete stress analysis showing that stresses imposed to

the pipe during and after installation of the HDD crossing will
meet the design requirements of reference iii);
b. A description of how the company will ensure that longitudinal
stresses during the installation will not exceed the SMYS of
the pipe.

RESPONSE

a. Please see the attached stress analysis of the pipe for the HDD installation based on
design and worst case scenarios. The stress analysis was prepared by J.D. Hair &
Associates (“JDH&A”), HDD consulting engineers for the project.

b. Please see the attached letter from JDH&A describing the stress analysis performed
and the suitability of the proposed line pipe for installation by HDD, including steps
established to ensure the HDD contractor does not exceed the specified minimum
yield strength of the pipe.
 Niagara Gas Information Request 1.4 - Attachment

2424 East 21st Street

J.D.Hair&Associates,Inc. Suite 510
Consulting Engineers Tulsa, Oklahoma 74114
Tel 918-747-9945
Fax 918-742-7408
www.jdhair.com

June 9, 2011

Niagara Gas Transmission Limited

900 Centennial Road
Brockville, ON, Canada K6V 5T4

Attn: Mr. Michael Tozer

SUBJECT: Analysis of HDD Installation Loads

Proposed 12-inch St. Lawrence River Crossing

Mr. Tozer:

In accordance with your request, we have completed an analysis of installation loads associated
with a 12-inch welded steel pipeline segment proposed for installation beneath the St. Lawrence
River by horizontal directional drilling (HDD). The objectives of this analysis were to confirm
the suitability of the proposed line pipe for installation by HDD, to determine an estimated
pulling load and establishing steps to ensure the HDD contractor will not exceed the specified
minimum yield strength. The results of our analysis are presented in this letter. Output pages
from our pulling load calculation routine are enclosed for your review.

Installation loads and stresses were evaluated using a method developed by J. D. Hair &
Associates, Inc. (JDH&A) for the Pipeline Research Committee at the American Gas
Association. A detailed explanation of this method may be found in Section 5 of Installation of
Pipelines by Horizontal Directional Drilling, An Engineering Design Guide1.

The information that was utilized in our analysis was provided by Enbridge/Niagara Gas and
consisted of the proposed line pipe specification, the pipeline’s maximum allowable operating
pressure and temperature. The proposed line pipe for the HDD crossing is 12.75-inch outside
diameter, 0.375-inch wall thickness, API 5L X-52 while the pipeline’s maximum operating
pressure and temperature are 3,515 kPa and 30°C (510 psi and 86 °F), respectively. Based on
this information, we first performed an operating stress analysis to determine the stresses at the
designed radius of 366 meters (1,200 feet) as it is laid out on the Drawing: “St Lawrence R0
(preliminary)” produced by JDH&A. At the design radius, the maximum shear stress is well
within the criteria outlined in ANSI B31.4 as shown in the attached “St. Lawrence River
(Metric)” spreadsheet. Next, we performed an operating stress analysis to determine the
1
Installation of Pipelines by Horizontal Directional Drilling, An Engineering Design Guide, prepared for the
Offshore and Onshore Design Applications Supervisory Committee of the Pipeline Research Committee at the
American Gas Association, J. D. Hair & Associates, Inc., Louis J. Capozzoli & Associates, Inc., and Stress
Engineering Services, Inc., April 15, 1995.
 Niagara Gas Information Request 1.4 - Attachment

Niagara Gas Transmission Limited

June 9, 2011
Page 2 of 3

minimum allowable radius with regard to operation. As indicated on the attached “St. Lawrence
River (Metric - Worst Case)” spreadsheets, we determined that the drilled radius is limited to a
minimum of 138 meters (454 feet) based on the maximum shear stress criteria outlined in ANSI
B31.4. This radius was then rounded up to 152 meters (500 feet) and used in our analysis of
installation stresses on the worst case design discussed below.

Our analysis of the proposed HDD installation was based on two drilled path models. The first
model conforms to the drilled path design presented on the drawing. It has a horizontal length of
769 meters and penetrates to a depth of approximately 26 meters below the entry point using an
entry angle of 12 degrees, an exit angle of 16 degrees and two sag bend curves with radii of 366
meters (1,200 feet). Based on this model, the anticipated installation load is 190 kN (42,698
pounds) and our calculations indicated no violations of applicable stress criteria.

Due to the fact that most HDD installations are drilled to greater depths and tighter radii than
designed, we also evaluated a “worst-case” model in order to verify that common deviations
from the designed profile would not result in unacceptable stress levels. This model has a
horizontal length of 789 meters and penetrates to a depth of 36.5 meters below the entry point
using an entry of 14 degrees, an exit angle of 18 degrees and two sag bend curves with radii of
152.39 meters (500 feet). Based on this worst-case model, the anticipated installation load is 255
kN (57,252 pounds) and our calculations again indicated no violations of applicable stress
criteria.

In reviewing these calculations, it should be noted that the pulling load determined by this
calculation method represents only the tensile load transmitted to the pull section as a result of
conditions in the hole. Loads resulting from the drill string, the reaming assembly that precedes
the pull section, and the above-ground portion of the pull section (typically supported on rollers)
are not included in the calculation. However, considering that the loads resulting from the drill
string and above-ground pipe approach zero as pullback nears completion, the estimated pulling
load presented herein for an installation along the designed profile should provide a reasonable
indication of the rig capacity required to pull the pipe assuming that pullback operations go well.
Based on our experience, a rig capacity of roughly twice this estimated load provides a sufficient
factor of safety in the event that reasonably foreseeable problems should occur.

Based on the calculations, we believe that the proposed line pipe is suitable for installation by
HDD beneath the St. Lawrence River and can be done while ensuring that longitudinal stresses
during the installation will not exceed the SMYS of the pipe. Our opinion is rooted in three
assumptions: 1) that the actual drilled path will not exceed the length or depth of the worst-case
model described in the following paragraphs; 2) that the HDD contractor will not employ any
improper construction procedures; and 3) that problematic subsurface conditions will not be
encountered.
 Niagara Gas Information Request 1.4 - Attachment

Niagara Gas Transmission Limited

June 9, 2011
Page 3 of 3

If you have any questions concerning this analysis, please don't hesitate to contact me.

Sincerely,

J. D. HAIR & ASSOCIATES, INC.

Dylan Bruntzel
Project Engineer

Enclosures
 Niagara Gas Information Request 1.4 - Attachment
PRCI Method, St. Lawrence River (Metric).xls
J:\Niagara Gas\1109-St. Lawrence River\Working\Stress Analysis\

Comments
Pulling load analysis based on the JDH&A design for the St. Lawrence River.

Line Pipe Properties

Pipe Outside Diameter, D = 12.750 in = 32.4 cm
Wall Thickness, t = 0.375 in = 1.0 cm
Specified Minimum Yield Strength (SMYS), F y = 52,000 psi = 3,656 kg/cm 2
Young's Modulus, E = 2.9E+07 psi = 2.E+06 kg/cm 2
Moment of Inertia, I = 1.16E+04 cm4
Pipe Face Surface Area = 94.06 cm2
Diameter to Wall Thickness Ratio = 34
Poisson's Ratio, ν = 0.3
Coefficient of Thermal Expansion, α = 1.2E-05 °C -1
Pipe Weight in Air = 73.76 kg/m
Pipe Interior Volume = 0.07 m3/m
Pipe Exterior Volume = 0.08 m3/m
HDD Installation Properties
Drilling Mud Density = 1,198 kg/m3
Ballast Density = 1,000 kg/m3
Coefficient of Soil Friction, μ = 0.30
Fluid Drag Coefficient, Cd = 0.025 psi = 1.76E-03 kg/cm 2
Ballast Weight = 72.93 kg/m
Displaced Mud Weight = 98.70 kg/m
Installation Stress Limits
Tensile Stress Limit, F t = 3,290 kg/cm 2
For D/t <= 1,500,000/SMYS, Fb = 2,742 kg/cm 2 No
For D/t > 1,500,000/SMYS and <= 3,000,000/SMYS, Fb = 2,683 kg/cm 2 Yes
For D/t > 3,000,000/SMYS and <= 300, Fb = 2,503 kg/cm 2 No
Allowable Bending Stress, Fb = 2,683 kg/cm 2
Elastic Hoop Buckling Stress, F he = 1,552 kg/cm 2
For Fhe <= 0.55*SMYS, Critical Hoop Buckling Stress, F hc = 1,552 kg/cm 2 Yes
For Fhe > 0.55*SMYS and <= 1.6*SMYS, Fhc = 1,925 kg/cm 2 No
For Fhe > 1.6*SMYS and <= 6.2*SMYS, Fhc = 1,366 kg/cm 2 No
For Fhe > 6.2*SMYS, Fhc = 3,656 kg/cm 2 No
Critical Hoop Buckling Stress, F hc = 1,552 kg/cm 2
Allowable Hoop Buckling Stress = 1,035 kg/cm 2
Operating Stress Check
Maximum Allowable Operating Pressure, P = 36 kg/cm 2
Radius of Curvature, R = 366 m
Installation Temperature, T1 = 10 °C
Maximum Operating Temperature, T2 = 30 °C
Groundwater Table Head, H = 0 m
Longitudinal Stress from Bending, f b = 903 kg/cm 2
% SMYS = 25%
Hoop Stress, fh = 610 kg/cm 2
% SMYS = 17%
Longitudinal Compressive Stress from Hoop Stress, f lh = 183 kg/cm 2
% SMYS = 5%
Longitudinal Stress from Thermal Expansion, fe = -477 kg/cm 2
% SMYS = 13%
Net Longitudinal Compressive Stress, fl = -1,197 kg/cm 2
% SMYS = 33%
Maximum Shear Stress = 903 kg/cm 2
Limited to 45% of SMYS by 402.3.1 of ASME/ANSI B 31.4 = 25% OK

Step 1, Property Input (Metric) 2:20 PM 6/9/2011

 PRCI Method, St. Lawrence River (Metric).xls
J:\Niagara Gas\1109-St. Lawrence River\Working\Stress Analysis\

Station Elevation Angle Radius Length Inclination Assumed Average Total Pull
Submerged Ballasted
(m) (m) (⁰) (m) (m) (⁰) Tension (kN) Tension (kN) (kN)
Entry Point 0.0 54.5 12.0 78.0 190
Entry Tangent 79.4 yes no 1 Not Used
PC 77.7 38.0 78.0 174
Entry Sag
PI 115.3 30.0 12.0 366 76.6 yes no 158 158
Bend
PT 153.7 30.0 90.0 0 142
Bottom Tangent 0.0 427.3 yes no 1 Not Used
PC 581.0 30.0 90.0 35
Exit Sag
PI 632.4 30.0 16.0 366 102.1 yes no 18 18
Bend
PT 681.8 44.2 106.0 0 1
Exit Tangent 90.8 no no 1 Not Used
Exit Point 769.1 69.2 16.0 106.0 Above Ground Load 0
True Length 776.3
Drilling Mud 54.5
Ballast
Niagara Gas Information Request 1.4 - Attachment

Step 2, Drilled Path Input (Metric) 2:20 PM 6/9/2011

 Niagara Gas Information Request 1.4 - Attachment
PRCI Method, St. Lawrence River (Metric).xls
J:\Niagara Gas\1109-St. Lawrence River\Working\Stress Analysis\

Weight &
Weight Bending External Hoop Tensile,
Tensile &
Point Fluidic Drag Friction Friction Total Pull Tensile Stress Bending Stress Stress Bending & Ext.
Bending Stress
Hoop Stress
(kN) (kN) (kN) (kN) (kg/cm 2) (kg/cm 2) (kg/cm 2)
Entry Point 120 35 34 190 206 ok 0 ok 0 ok 0.06 ok 0.00 ok
189 ok 0 ok 34 ok 0.06 ok 0.01 ok
PC 106 34 34 174
189 ok 903 ok 34 ok 0.39 ok 0.14 ok
154 ok 903 ok 50 ok 0.38 ok 0.14 ok
PT 93 36 13 142
154 ok 0 ok 50 ok 0.05 ok 0.01 ok
38 ok 0 ok 50 ok 0.01 ok 0.00 ok
PC 18 4 13 35
38 ok 903 ok 50 ok 0.35 ok 0.11 ok
1 ok 903 ok 21 ok 0.34 ok 0.10 ok
PT 0 1 0 1
1 ok 0 ok 21 ok 0.00 ok 0.00 ok
0 ok 0 ok 0 ok 0.00 ok 0.00 ok
Exit Point 0 0 0 0

Step 3, Results Output (Metric) 2:20 PM 6/9/2011

 Niagara Gas Information Request 1.4 - Attachment
PRCI Method, St. Lawrence River (Metric - Worst Case).xls
J:\Niagara Gas\1109-St. Lawrence River\Working\

Comments
Pulling load analysis based on the JDH&A worst case design for the St. Lawrence River. The design incorporates an entry angle of 14
degrees, an exit angle of 18 degrees, radii of 152.39 meters (500 feet), while being 10 meters deeper and 20 meters longer than original
design.

Line Pipe Properties

Pipe Outside Diameter, D = 12.750 in = 32.4 cm
Wall Thickness, t = 0.375 in = 1.0 cm
Specified Minimum Yield Strength (SMYS), F y = 52,000 psi = 3,656 kg/cm 2
Young's Modulus, E = 2.9E+07 psi = 2.E+06 kg/cm 2
Moment of Inertia, I = 1.16E+04 cm4
Pipe Face Surface Area = 94.06 cm2
Diameter to Wall Thickness Ratio = 34
Poisson's Ratio, ν = 0.3
Coefficient of Thermal Expansion, α = 1.2E-05 °C -1
Pipe Weight in Air = 73.76 kg/m
Pipe Interior Volume = 0.07 m3/m
Pipe Exterior Volume = 0.08 m3/m
HDD Installation Properties
Drilling Mud Density = 1,198 kg/m3
Ballast Density = 1,000 kg/m3
Coefficient of Soil Friction, μ = 0.30
Fluid Drag Coefficient, Cd = 0.025 psi = 1.76E-03 kg/cm 2
Ballast Weight = 72.93 kg/m
Displaced Mud Weight = 98.70 kg/m
Installation Stress Limits
Tensile Stress Limit, F t = 3,290 kg/cm 2
For D/t <= 1,500,000/SMYS, Fb = 2,742 kg/cm 2 No
For D/t > 1,500,000/SMYS and <= 3,000,000/SMYS, Fb = 2,683 kg/cm 2 Yes
For D/t > 3,000,000/SMYS and <= 300, Fb = 2,503 kg/cm 2 No
Allowable Bending Stress, Fb = 2,683 kg/cm 2
Elastic Hoop Buckling Stress, F he = 1,552 kg/cm 2
For Fhe <= 0.55*SMYS, Critical Hoop Buckling Stress, F hc = 1,552 kg/cm 2 Yes
For Fhe > 0.55*SMYS and <= 1.6*SMYS, Fhc = 1,925 kg/cm 2 No
For Fhe > 1.6*SMYS and <= 6.2*SMYS, Fhc = 1,366 kg/cm 2 No
For Fhe > 6.2*SMYS, Fhc = 3,656 kg/cm 2 No
Critical Hoop Buckling Stress, F hc = 1,552 kg/cm 2
Allowable Hoop Buckling Stress = 1,035 kg/cm 2
Operating Stress Check
Maximum Allowable Operating Pressure, P = 36 kg/cm 2
Radius of Curvature, R = 138 m
Installation Temperature, T1 = 10 °C
Maximum Operating Temperature, T2 = 30 °C
Groundwater Table Head, H = 0 m
Longitudinal Stress from Bending, f b = 2,386 kg/cm 2
% SMYS = 65%
Hoop Stress, fh = 610 kg/cm 2
% SMYS = 17%
Longitudinal Compressive Stress from Hoop Stress, f lh = 183 kg/cm 2
% SMYS = 5%
Longitudinal Stress from Thermal Expansion, fe = -477 kg/cm 2
% SMYS = 13%
Net Longitudinal Compressive Stress, fl = -2,680 kg/cm 2
% SMYS = 73%
Maximum Shear Stress = 1,645 kg/cm 2
Limited to 45% of SMYS by 402.3.1 of ASME/ANSI B 31.4 = 45% OK

Step 1, Property Input (Metric) 12:56 PM 6/9/2011

 PRCI Method, St. Lawrence River (Metric - Worst Case).xls
J:\Niagara Gas\1109-St. Lawrence River\Working\

Station Elevation Angle Radius Length Inclination Assumed Average Total Pull
Submerged Ballasted
(m) (m) (⁰) (m) (m) (⁰) Tension (kN) Tension (kN) (kN)
Entry Point 0.0 54.5 14.0 76.0 255
Entry Tangent 127.5 yes no 1 Not Used
PC 123.7 23.7 76.0 231
Entry Sag
PI 141.9 19.1 14.0 152 37.2 yes no 210 210
Bend
PT 160.6 19.1 90.0 0 189
Bottom Tangent 0.0 449.3 yes no 1 Not Used
PC 609.9 19.1 90.0 77
Exit Sag
PI 634.1 19.1 18.0 152 47.9 yes no 61 61
Bend
PT 657.0 26.6 108.0 0 45
Exit Tangent 138.9 yes no 1 Not Used
Exit Point 789.1 69.5 18.0 108.0 Above Ground Load 0
True Length 800.8
Drilling Mud 54.5
Ballast
Niagara Gas Information Request 1.4 - Attachment

Step 2, Drilled Path Input (Metric) 12:56 PM 6/9/2011

 Niagara Gas Information Request 1.4 - Attachment
PRCI Method, St. Lawrence River (Metric - Worst Case).xls
J:\Niagara Gas\1109-St. Lawrence River\Working\

Weight &
Weight Bending External Hoop Tensile,
Tensile &
Point Fluidic Drag Friction Friction Total Pull Tensile Stress Bending Stress Stress Bending & Ext.
Bending Stress
Hoop Stress
(kN) (kN) (kN) (kN) (kg/cm 2) (kg/cm 2) (kg/cm 2)
Entry Point 140 55 59 255 276 ok 0 ok 0 ok 0.08 ok 0.01 ok
250 ok 0 ok 63 ok 0.08 ok 0.01 ok
PC 118 54 59 231
250 ok 2,166 ok 63 ok 0.88 ok 0.70 ok
205 ok 2,166 ok 72 ok 0.87 ok 0.68 ok
PT 112 55 23 189
205 ok 0 ok 72 ok 0.06 ok 0.01 ok
84 ok 0 ok 72 ok 0.03 ok 0.01 ok
PC 33 22 23 77
84 ok 2,166 ok 72 ok 0.83 ok 0.61 ok
48 ok 2,166 ok 57 ok 0.82 ok 0.59 ok
PT 24 20 0 45
48 ok 0 ok 57 ok 0.01 ok 0.00 ok
0 ok 0 ok -31 ok 0.00 ok 0.00 ok
Exit Point 0 0 0 0

Step 3, Results Output (Metric) 12:56 PM 6/9/2011

 Filed: 2011-06-09
Niagara Gas Transmission Limited
St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 5
Page 1 of 2
Plus Attachment

NATIONAL ENERGY BOARD INFORMATION REQUEST 1.5

Security Matters

1.5 Manuals

Reference: i. Filing A1Y7W9 – Niagara Gas Application

ii. Filing A1S7H7, NEB Document: Proposed Regulatory Change
2010-01 (PCR 2010-01)
iii. CSA Z246.1-09, Security Management for Petroleum and Natural
Gas Industry Systems

Preamble: PRC 2010-01 sets out the NEB’s requirement for a company to
have a security program that is in accordance with
CSA Z246.1-09. Specifically PRC 2010-01 states:

Companies shall develop, document, implement and

maintain a security program that is in accordance with CSA
Z246.1-09, Security Management for Petroleum and Natural
Gas Industry Systems, as amended from time to time

Request: Please confirm that Niagara Gas:

a. is aware and will comply PRC 2010-01. If not, please justify

why not.
b. has conducted and documented a security assessment for the
project. If not, please justify why not.
c. has developed a security management plan for the project. If
not, please justify why not.

RESPONSE

a. Niagara Gas is aware of the proposed regulatory change (PRC 2010-01) and will
follow the provisions of Section 9.2 Facility Design and Construction as per CSA
Z246.1-09 Security Management for the Petroleum and Natural Gas Industry
Systems.

b. An on-site security assessment will be conducted no later than June 30, 2011.
 Filed: 2011-06-09
Niagara Gas Transmission Limited
St. Lawrence River Pipeline Crossing Replacement Project
NEB File No.: OF-Fac-Gas-N213-2011-01 02
Information Request No. 1
Schedule 5
Page 2 of 2
Plus Attachment

c. A security management plan framework for the project has been developed and is
attached. The framework identifies the elements of the security management plan to
be developed for the project after the security assessment is conducted.
 Niagara Gas Information Request 1.5 - Attachment
Cornwall Bridge Relocation Project Security Management Plan Framework

SECURITY
MANAGEMENT PLAN
FRAMEWORK
2011 Cornwall Bridge Relocation Project

Contact the Enbridge Gas Distribution Inc. (“EGD”) Corporate

Security Department with any questions related to this document.

1
 Niagara Gas Information Request 1.5 - Attachment
Cornwall Bridge Relocation Project Security Management Plan Framework

1.0 PURPOSE

Security Governance

The Cornwall Bridge Relocation Project Security Management Plan,

further described below, is intended to reduce the vulnerability of
employees, contractors, the public, and facilities to security threats.
Security governance involves setting project procedures that define how
the Security Management Plan should be appropriately integrated into the
overall management systems of the entity that has primary responsibility
for the project (“Prime Contractor”). Security governance includes
management commitment and accountability. Security Procedures
provide clear direction, commitment, responsibility, oversight and define
the security environment for the Cornwall Bridge Relocation Project.

2.0 SCOPE

This Security Management Plan Framework applies to the Cornwall

Bridge Relocation Project.

3.0 RESPONSIBILITIES

3.1 EGD Corporate Security Department

• Provide security management advice and continuous support to the

Prime Contractor.

3.2 Project Management (off-Site)

• Ensure full implementation of all provisions of the Security

Management Plan.
• Verify that a Security Management Plan has been developed for
the project.
• Review the Security Management Plan prior to distribution.
• Verify the project is compliant with the Security Management Plan
Framework.
• Make available sufficient resources to provide ongoing technical
support and training for the Prime Contractor in the identification

2
 Niagara Gas Information Request 1.5 - Attachment
Cornwall Bridge Relocation Project Security Management Plan Framework

and implementation of project specific requirements pursuant to the

Security Management Plan Framework.

3.2 Project Management (Site)

• Review and approve the Security Management Plan prior to

mobilization.
• Complete revisions to the Security Management Plan as project
conditions change.
• Make contractors aware of the provisions in the Security
Management Plan.
• Ensure that the Prime Contractor is in compliance with the overall
provisions of the Security Management Plan.

4.0 PROJECT SECURITY MANAGEMENT

4.1 Security Management Plan Defined

The Prime Contractor shall have documented security procedures

(“Security Management Plan”) to ensure that security incidents are
identified and associated risks are managed with appropriate safeguards
and response procedures to minimize the impact of security incidents
adversely affecting people, property, the environment, and the economic
viability of the project and the Prime Contractor.

The provisions of the Security Management Plan are intended to be

applicable to the Prime Contractor, and all third party contractors
regardless of their role in the project.

4.2 Prime Contractor Accountability

The Prime Contractor shall establish a framework of security management

accountability. This framework shall establish roles and responsibilities for
the control, review, continuous improvement and approval of the Security
Management Plan across the construction project.

5.0 SECURITY RISK MANAGEMENT

5.1 General

The security risk management process provides the flexibility needed for
proactive decision making to address the security risks to the project. The
Prime Contractor identifies and classifies security risks in order to develop

3
 Niagara Gas Information Request 1.5 - Attachment
Cornwall Bridge Relocation Project Security Management Plan Framework

and implement strategies and security controls to eliminate or mitigate risk

to assets. Security risk management activities should be commensurate
with the type, size, location, and criticality of the assets being protected.
Risk should be continuously assessed during the project by determining
the likelihood of potential threats and impact if the threat is realized.

5.2 Risk Management Process

The risk management process shall include:

• Asset characterization – measure the criticality of assets

• Threat Assessment – identify current and potential threats that
could result in loss of or damage to an asset
• Vulnerability Assessment – identify existing safeguards or
countermeasures and determine the efficacy of existing security
countermeasures
• Risk Assessment – assess based on a combination of criticality,
potential threats, and vulnerability of an asset
• Risk Mitigation – evaluate, prioritize, and implement available
countermeasures to reduce vulnerabilities or consequence
• Communications and recommendations – communicate findings
and recommendations internally

6.0 SECURITY INCIDENT MANAGEMENT

6.1 General

Security incident management addresses the capability of the Prime

Contractor to respond to security-related threats and incidents. Security
incident is dependent on implementing processes and procedures for
incident response, monitoring, handling, reporting, and recovery.

6.2 Process

The Prime Contractor shall develop a formal documented Security

Incident Procedure that specifies how the Prime Contractor will respond to
and recover from security-related threats or incidents.

6.2 Planning

Security incident management planning shall include:

• Providing employees and third party contractors with Security

Incident response, notification and reporting procedures
• Identification of local law enforcement agencies to contact in the
event of a security threat or incident

4
 Niagara Gas Information Request 1.5 - Attachment
Cornwall Bridge Relocation Project Security Management Plan Framework

• Creation of a communication procedure contact list

• Creation of a security incident report log and records preservation
system to serve as an official record of actions taken and lessons
learned for post-incident review

6.3 Incident Documentation

The Prime Contractor shall document security-related threats and

incidents which will be maintained for inspection.

6.3 Records and Documentation

The Prime Contractor shall maintain a security records management

system.

6.4 Incident Response

The Prime Contractor shall develop and implement a security incident

response procedure.

6.5 Incident Reporting

The Prime Contractor shall develop and implement security incident

reporting procedures.

6.6 External Reporting

The Prime Contractor shall develop and implement security incident

reporting procedures to notify law enforcement and other appropriate
agencies of security-related incidents.

6.7 Security Threats

The Prime Contractor shall have a process in place to communicate to

employees and all on-site personnel information related to potential
security threats.

6.8 Evacuation Planning

The Prime Contractor shall include procedures to direct people away from
the construction site, including provisions to account for people that have
been evacuated from the construction site.

6.9 Investigations

The Prime Contractor with support from the EGD Corporate Security
department shall develop and implement a process to conduct security-
related investigations.

5
 Niagara Gas Information Request 1.5 - Attachment
Cornwall Bridge Relocation Project Security Management Plan Framework

7.0 PHYSICAL SECURITY

On-site security measures must reflect the size, location, risk, and
criticality of the assets that require protection. Security risks to people, the
environment, assets, or economic stability to the project shall be taken into
account when determining the degree of physical security that is required.
Physical security measures shall consider:

• Fencing and gates to protect against unauthorized entry

• Appropriate signage to be posted (e.g., “No Trespassing/Authorized
Personnel Only”)
• Lighting with sufficient illumination to identify persons and vehicles
as well as security concerns
• Access control
• Locks and key control
• Equipment security
• Uniformed security officers if conditions require the use of on-site
security guards
• After hours security procedures
• Sign-in and sign-out procedures
• Proper locks on storage containers

8.0 CHANGE MANAGEMENT PROCESS

The Prime Contractor shall develop, document and implement a process

for the management of changes that could have a significant impact on
the effectiveness of the Security Management Plan.

9.0 VALIDATION AND EVALUATION

The Prime Contractor shall conduct a formal review of the Security

Management Plan at regular intervals during the construction project. The
review shall verify the Plan’s continuing suitability, adequacy, and
effectiveness. The review shall also identify opportunities for improvement
and the need for changes.

10 TRAINING AND AWARENESS

The Prime Contractor shall conduct project specific security training and
awareness sessions to all on-site personnel which outlines the provisions
of the Security Management Plan.

6
 Niagara Gas Information Request 1.5 - Attachment
Cornwall Bridge Relocation Project Security Management Plan Framework

11 REFERENCES

The Prime Contractor shall consider the elements contained within the
Canadian Standards Association Z246.1, Security management for
petroleum and natural gas industry systems when developing and
implementing the Security Management Plan.