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TRANSCANADA OPERATING PROCEDURE (PROCEDURE) Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 1 of 16 Document Owner: Shannon Phillips 1.0 PURPOSE The purpose of this Procedure is to describe the methods of dealing with pipeline Right-Of-Way (ROW) identification issues, insufficient pipeline cover and erosion problems 2.0 SCOPE This Procedure applies to Pipeline ROWs for all US, Canada, and Mexico assets which are wholly owned and operated by TransCanada as well as all Partially Owned Entities and/or Joint ventures where TransCanada has operational control. This procedure applies to both liquid and gas transmission pipelines located within the US, Canada, and Mexico. 3.0 REFERENCES All TOP documents can be accessed from the TOPs database using this link TOPs. Note: TOP documents referenced in this document will have their titles underlined and can be opened up by using the hyperlink below or going to the TOPs database using the above TOPs link. One-Call Locating and Marking Procedures U.S. and Mexico (EDMS No. 003857331) TransCanada Signage Procedure (EDMS No. 003887955) TransCanada Online Signage Catalogue TransCanada Brand Standards TES-PROJ-PCS-US Pipeline Construction Specification (EDMS No. 004461071) TES-PROJ-PCS Pipeline Construction Specification (CDN) (EDMS No. 003745282) TES-PROJ-EXC Excavation Specification (Cdn-US-Mex) (EDMS No. 005890120) Stakeout Report and Ground Disturbance Approval (EDMS No. 003841204) STDS-03-ML-03-501 High Pressure Gas Warning Sign Pipeline Insufficient Cover Initial Inspection Form (Under Development) Success Factors Excavation TOP Review and Test (Course #71008265) Success Factors Excavation Orientation (Course #71008480) Excavation Procedure (EDMS No. 003672343) One Call Location and Marking Procedure U.S. and Mexico (EDMS No. 003857331) Wetland Watercourses and Waterbody Protection Procedure Canada (EDMS No 005518290) Wetland Watercourses and Waterbody Protection Procedure US (EDMS No. 005529843) Fish and Wildlife Protection Procedure Canada (EDMS No. 005518305) Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

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TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 1 of 16

Document Owner: Shannon Phillips

1.0 PURPOSE

The purpose of this Procedure is to describe the methods of dealing with pipeline Right-Of-Way (ROW) identification issues, insufficient pipeline cover and erosion problems

2.0 SCOPE

This Procedure applies to Pipeline ROWs for all US, Canada, and Mexico assets which are wholly owned and operated by TransCanada as well as all Partially Owned Entities and/or Joint ventures where TransCanada has operational control. This procedure applies to both liquid and gas transmission pipelines located within the US, Canada, and Mexico.

3.0 REFERENCES

• All TOP documents can be accessed from the TOPs database using this link TOPs. Note: TOP documents referenced in this document will have their titles underlined and can be opened up by using the hyperlink below or going to the TOPs database using the above TOPs link.

• One-Call Locating and Marking Procedures U.S. and Mexico (EDMS No. 003857331)

• TransCanada Signage Procedure (EDMS No. 003887955)

• TransCanada Online Signage Catalogue

• TransCanada Brand Standards

• TES-PROJ-PCS-US Pipeline Construction Specification (EDMS No. 004461071)

• TES-PROJ-PCS Pipeline Construction Specification (CDN) (EDMS No. 003745282)

• TES-PROJ-EXC Excavation Specification (Cdn-US-Mex) (EDMS No. 005890120)

• Stakeout Report and Ground Disturbance Approval (EDMS No. 003841204)

• STDS-03-ML-03-501 High Pressure Gas Warning Sign

• Pipeline Insufficient Cover Initial Inspection Form (Under Development)

• Success Factors Excavation TOP Review and Test (Course #71008265)

• Success Factors Excavation Orientation (Course #71008480)

• Excavation Procedure (EDMS No. 003672343)

• One Call Location and Marking Procedure U.S. and Mexico (EDMS No. 003857331)

• Wetland Watercourses and Waterbody Protection Procedure Canada (EDMS No 005518290)

• Wetland Watercourses and Waterbody Protection Procedure US (EDMS No. 005529843)

• Fish and Wildlife Protection Procedure Canada (EDMS No. 005518305)

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 2 of 16

• Fish and Wildlife Protection Procedure US (EDMS No. 005529817)

• Alberta Energy Regulator Gas Transmission Reporting Requirements (EDMS No. 006214639)

• Alberta Energy Regulator Gas Storage Facility Reporting Requirements (EDMS No. 003948357

• PHMSA Special Permit PHMSA-2006-26617 KeyUS Design Factor 0.80 – Liquids (EDMS No. 008516082)

• Department of State Final Supplemental Environmental Impact Statement Appendix B – Potential Releases and Pipeline Safety

• Common Ground Alliance Best Practices 12.0

• Issue Management Procedure (EDMS No. 008174809)

4.0 PROCEDURE

4.1 Right-Of-Way Identification

4.2 Depth of Cover

4.3 Insufficient Cover

5.0 Documentation / Reporting Requirements

6.0 Definitions

Appendix A Erosion / Insufficient Cover Issue Workflow

Appendix B RACI Chart – Erosion / Insufficient Cover Workflow

Notes:

1. Each Activity should be performed after reviewing the appropriate TOP Procedures (Example Safety, Environmental, Health Hygiene etc.).

2. All signage to be Owner supplied and must meet the specifications outlined in the TransCanada Signage Procedure.

Hazards: The Document Owner has presently not identified any hazards for stakeholders with respect to this document.

Qualification Requirement(s): Ensure TransCanada employees conducting or supervising the activities described in this TOP are properly trained as defined in the Learning Management System (LMS)

(U.S. only): TransCanada is required to have a Qualifications Program under U.S. Department of Transportation (DOT) 46 CFR 192.805 Transportation of Gas Regulation and 49 CFR 195.505 Transportation of Hazardous Liquids by Pipeline. Some activities involved with excavation are covered under TransCanada’s Operator Qualification (OQ) Program and must be performed by qualified individuals.

Note: Employees have the obligation and right to refuse to perform work they feel is unsafe. If they believe an activity is unsafe they should consult with peers, leaders and safety personnel to determine if the activity is indeed unsafe and the safest way to proceed. This can include not performing the work, transfer the work to individuals with proper training to perform the hazardous work or develop appropriate controls to ensure safety.

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 3 of 16

Special Resources: Access to the TransCanada Online Signage Catalogue is required. The Catalogue can only be accessed while logged into TransCanada’s Network and a valid TransCanada email address is required.

4.1 Right-Of-Way Identification

1. The signage products available through the TransCanada Online Signage Catalogue have been reviewed and approved by internal stakeholders, including subject matter experts and communications teams, as meeting regulatory and TransCanada requirements

2. The TransCanada Signage Procedure outlines the requirements for signage and messaging

3. Multiple versions of each “Sign Type” are provided in the TransCanada Online Signage Catalogue due to regional or asset based messaging requirements. Carefully read the product description to ensure the product is suitable for its intended purpose. It is the responsibility of the manager accountable for the operation of the area or region to ensure that the correct signage is ordered and mounted.

4. It is the responsibility of the Field Technicians to inspect all signs to identify damaged, worn, vandalized or missing signs and repair and/or replace as necessary. As long as the existing signage meets all regulatory requirements for content, signage does not need to be updated to current signage, and shall be updated and replaced in the future as necessary.

5. The standard ROW Signage are as follows in Figure 1 below:

Figure 1: High Pressure Natural Gas / Hazardous Liquids Warning Signage

6. In Canada and the US, there are two standard high pressure natural gas / hazardous liquids warning signs, Type 1 and Type 2 as shown above in Figure 1 (referred to as “Warning Signs”). These signs can be used interchangeably for ROW marking. When selecting the signage from the online catalogue, ensure that the correct signage for the applicable region is being selected.

7. In Mexico, the standard High Pressure Natural Gas warning sign (“Mexico Warning Sign”), Type 3 as shown above in Figure 1, is not currently available through the online catalogue. Ensure that signage that is being ordered for Mexico has the appropriate and required messaging for the area that it is being installed.

8. The following must be written legibly in permanent black lettering on a yellow background:

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 4 of 16

a. The word “Warning”, “Caution” or “Danger” followed underneath by the type of pipeline (e.g.

“High Pressure Natural Gas Pipeline” or “High Pressure Oil Pipeline”). All letters shall be 25mm (1 inch) high and 6.35mm (¼ inch) stroke.

b. The name of the operator (e.g. TransCanada) and telephone number (including area code) where the operator can be reached at all times (emergency number).

c. “Call Before You Dig”, and One Call Center Phone Number if possible (e.g. 811, Alberta One-Call ect)

Mexico Only:

1. The signs must be on a yellow background with black letters, and shall include the following:

a. “PRECAUCION Tubería a Presión Bajo Tierra, Gas Natural”; b. “no cavar, no golpear, no construir”.

Note: This phrase can be in letters or a symbol; c. “Derecho de vía XX metros”; d. “Informes a 01-800-111-3333”; and e. The name of the appropriate line of business (e.g. “Transportadora de Gas Natural de La

Huasteca, S de RL, de CV”, “Energía Occidente de Mexico S. De RL De C.V.” or “Transportadora de Gas Natural del Noroeste”).

2. All letters shall be 25mm (1 inch) high and 6.35mm (¼ inch) stroke.

TQM, NGTL and Foothills Systems Only:

1. Along the TQM, NGTL and Foothills Systems, in addition to the Warning Signs, marker posts, as shown in Figure 2 below, shall also be installed.

Figure 2: TQM, NGTL and Foothills Systems Warning Markers

4.1.1 Location of Marker Signs

4.1.1.1 Crossings

1. Warning Signs shall be installed on both sides of all:

a. public roads; b. railroads;

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 5 of 16

c. Overhead crossings (Mexico); d. Rivers, creeks and other bodies of water.

Figure 3: Signage Requirements for Crossings

2. Consideration shall be given to the installation of warning signs on both sides of private roads, trails and undeveloped road allowances

Canada Only

1. Where a pipeline was installed using Horizontal Directional Drilling (HDD) methods to cross a navigable waterway (i.e. The St Lawrence Waterway), and where the pipe is well below the river bottom, “No Anchorage / No Dredging” signage is not required. In cases where an open-cut method was used to install the pipelines on these waterways, then “No Anchorage / No Dredging” signage is required.

4.1.1.2 Right-of-Way

1. Warning Signs shall be installed, where practicable, with line of sight spacing to ensure that at any point along the ROW, the route of the pipeline is clearly identified, with no more than 500m (1640 ft) between signage, see Figure 4 below.

Figure 4: Line of Sight Placement of Warning Signs

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 6 of 16

2. Warning Signs shall be placed as close as practical to, or over the centerline of each buried

transmission line, see Figure 5 below. Necessary precautions shall be employed to ensure no coating or pipe damage results from the installation of the signage.

Figure 5: Placement of Warning Signs in Reference to Pipeline Centerline

3. Warning Signage shall be placed at any other location necessary to reduce the possibility of damage or interference. Consideration shall be given to placing signage at the following locations:

a. Fence lines; b. Bends greater than 30 degrees, including composite or multiple bends – it is recommended that

signage be placed directly above the bend, with additional signage 10 meters (30 ft) upstream and 10 meters (30 ft) downstream of the bend. See Figure 6 below;

Figure 6: Signage Requirements at Horizontal Bends 30 Degrees and Greater

c. Utility corridors; d. Subdivision developments; e. Construction activity; f. Drainage and Irrigation Systems; g. Other anticipated third-party activity.

4. To aid in identifying pipelines, considerations should be given to applying the applicable pipeline name/number to the back of the sign. E.g. Line 100-1, Line 2000, Line A etc

NGTL and Foothills Pipeline Systems Only

1. In addition to the Warning Signs along the ROW, marker posts shall be installed one meter on either side of the pipeline centerline, as shown in Figure 7 below. NGTL and British Columbia Pipeline Systems shall use an orange post with a white top, while the Foothills Pipeline System shall use a green post with a white top.

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 7 of 16

Note: Most existing marker posts along the Foothills Pipeline System are presently on the ROW boundaries. When replacing or repairing marker posts, they should be placed one meter either side of the pipe centerline. There is no regulatory requirement for ROW Limit Markers.

Figure 7: NGTL and Foothills Systems Warning Posts

TQM Only

1. TQM Warning Signs are placed 1m to the right of the centerline of the pipeline when looking downstream.

2. In addition to the Warning Signs, white with blue top ROW Markers are placed at the limits of the ROW along the TQM system, as shown below in Figure 8.

Figure 8: TQM Warning Posts

US Only

1. Pipelines operating using the Alternative Maximum Allowable Operating Pressure (AMAOP) (e.g. Bison Pipeline) must employ line-of-sight signage on the pipeline, except in agricultural areas, large water crossings, swamps, steep terrain, or where prohibited by Federal Energy Regulatory Commission orders, permits, or local law.

2. Keystone Pipeline must employ line-of-sight markings on the pipeline except in agricultural areas or large water crossings, such as lakes, where line of sight markers are impractical. Additional markers must be placed along the pipeline in areas where the pipeline is buried less than 48 inches (1.2m).

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 8 of 16

Mexico Only

1. Mexico Warning Signs shall be placed on the edge of the Permanent ROW – No requirement to place signage over centerline of pipeline, as shown in Figure 9 below.

Figure 9: Placement Requirements for Mexico Warning Signs

2. Mexico Warning Signs shall be placed at all bends greater than 30 degrees

4.2 Depth of Cover

4.2.1 Minimum Depth of Cover - Original Construction

1. Regulations and Standards dictate the minimum necessary cover requirements for pipelines during their initial construction. The Company's standards meet or exceed these standards. The intent is to maintain sufficient cover to protect the pipeline from damage by encroachment and land use.

In the U.S.A

1. The DOT 49 Code of Federal Regulations (CFR) Regulatory construction standards and Related Special Permit Approvals are as follows:

Location Cover - Natural Gas Pipeline Cover – Keystone Pipeline

Normal Soil Consolidated Rock Normal Soil Consolidated

Rock

Class 1 Locations 30 in (0.75m) 18 in (0.45m) 48 in (1.2m) 36 in (0.9m)

Class 2, 3 & 4 Locations 36 in (0.9m) 24 in (0.6m) 48 in (1.2m) 36 in (0.9m)

Drainage ditches of public roads and railway crossings 36 in (0.9m) 24 in (0.6m) 48 in (1.2m) 36 in (0.9m)

River Crossings 48 in (1.2m) 24 in (0.6m) 48 in (1.2m) 18 in (0.45m)

Industrial, Commercial and Residential areas N/A N/A 48 in (1.2m) 30 in (0.75m)

AMAOP Pipelines

1. Minimum depth of cover for AMAOP pipelines (e.g. Bison) is 48” (1.2m) in agricultural areas, and 36” (0.9m) elsewhere.

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 9 of 16

2. When observed conditions indicate the possible loss of cover, perform a depth of cover study along

the pipeline and replace cover to meet the minimum depth requirements or apply other mititgative measures to provide protection equivalent to the originally required depth of cover.

Keystone Pipeline Special Permit Conditions

1. The soil cover for the Keystone pipeline System must be maintained at a minimum depth of 48 inches (1.2m) in all cultivated areas, 42 inches (1.0m) in other areas, and 36 inches (0.9m) in consolidated rock.

2. Along the Keystone Pipeline, if routine patrols indicate the possible loss of cover over the pipeline, a depth of cover survey must be completed, and the depth of cover shall be restored as soon as practicable, but not to exceed 6 months, to meet the minimum depth of cover requirements specified.

3. In areas where conditions prevent the maintenance of 48 inches (1.2m) of cover, additional protective measures must be employed to alert the public and excavators to the presence of the pipeline. The additional measures shall include placing warning tape and additional pipeline signage along the affected pipeline segment

4. Keystone must perform a detailed depth-of-cover survey along the entire Keystone pipeline as frequently as practicable, not to exceed once every 10 years, and replace cover as required as soon as practicable, not to exceed 6 months.

5. In areas where the Keystone Pipeline is susceptible to threats from chisel plowing or other activities, the top of the pipeline must be installed at least one foot (0.3m) below the deepest penetration of the plow.

In Canada

The CSA Z662-14 and AER Pipeline Rules Regulatory construction standards for Canada are as follows:

Location

Cover - Natural Gas Pipeline Cover - LVP Pipeline

NEB Regulated Pipelines AER Regulated Pipelines

Normal Soil Consolidated Rock

Normal Soil Consolidated Rock Normal Soil

Class 1, 2, 3 &4 Locations 0.60 m (24 in) 0.60 m (24 in) 0.80 m (31.5 in) 0.60 m (24in) 0.60 m (24 in)

ROW (Road or Railway) 0.75 m (30 in) 0.75 m (30 in) 1.1m (43 in) 0.75 m (30 in) 0.75 m (30 in)

Below Travelled surface (road) 1.20 m (48 in) 1.20 m (48 in) 1.4m (55 in) 1.20 m (48 in) 1.20 m (48 in)

Below base of rail (railway) Cased Uncased

1.20 m (48 in) 2.00 m (80 in)

1.20 m (48 in) 2.00 m (80 in)

1.20 m (48 in) 2.00 m (80 in)

1.20 m (48 in) 2.00 m (80 in)

1.20 m (48 in) 2.00 m (80 in)

Water Crossing 1.20 m (48 in) 0.60 m (24 in) 1.20 m (48 in) 1.20 m (48 in) 0.60 m (24 in)

Drainage or irrigation ditch invert 0.75 m (30 in) 0.60 m (24 in) 0.75 m (30 in) 0.75 m (30 in) 0.60 m (24 in)

Note: For a complete list of AER Regulated pipelines in Alberta, refer to Appendix A of the Alberta Energy Regulator Gas Transmission Reporting Requirements and Appendix A of the Alberta Energy Regulator Gas Storage Facility Reporting Requirements.

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 10 of 16

In Mexico

The NOM-007-SECRE-2010 Comisión Reguladora de Energía (CRE) Regulatory construction standards for Mexico are as follows:

Location Cover – Natural Gas Pipelines

Normal Soil Consolidated Rock

Class 1 & 2 Locations 0.60m (24 in) 0.45m (18 in)

Class 3 & 4 Locations 0.75m (30 in) 0.60m (24 in)

Drainage ditches of public roads crossings 0.9m (35 in) 0.60m (24 in)

River Crossings 1.2m (48 in) 0.60m (24 in)

Railroad Crossings* 1.2m (48 in) 1.2m (48in) *Cased Crossings

Note: In the areas where agricultural activities can be carried out that require deep plowing, in areas subjected to erosion, or in areas where the construction of highways, railways, among others are planned, additional protection or burial of the pipeline at a greater depth must be considered.

4.2.2 Insufficient Cover

1. Locations with insufficient cover will normally be detected through a third party application to cross the right-of-way, maintenance and integrity work, landowner concerns or via aerial or ground patrol reports

2. Even though an area may meet the original cover criteria, present land use may require additional protection. For example, if drainage ditches are deepened or erosion or land uses have caused a loss of the original cover

3. Any area with insufficient cover shall be entered into SAP with a G0 Notification

4. The Region may repair minor soil subsidence that can be repaired by a few loads of soil

Keystone US Only

1. If possible loss of cover over the US portion of the Keystone pipeline is discovered through patrols, routine maintenance, or other means, Keystone must perform a depth-of-cover survey and replace cover as soon as possible, not to exceed 6 months, to meet the minimum depth of cover requirements specified.

4.3 Insufficient Cover

1. The requirement for erosion maintenance shall be identified by aerial patrol reports, ground based patrol reports, General Public Notifications, or other inspections of the pipeline ROW.

2. Any erosion issues identified through the water crossing program, a SAP G0 General Issue Notification will be entered by the Weather and Outside Force Team within Pipe Integrity. All other erosion issues identified shall be entered in to SAP as a G0 General Issue Notification by the Region. For additional details on G0 General Issue Notifications, see the Issue Management Procedure. For full Workflow, and associated RACI Chart, see Appendix A and Appendix B respectively.

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 11 of 16

3. Within the Long Text Box of the Description in G0 notification, at a minimum, the following

information is required:

a. GPS location, b. Pipeline affected, and c. General description of issue identified

4. Photos of any erosional issues shall include at least one photo along the pipeline alignment(s) showing current issue and surrounding area, one photo in one direction including the surrounding area, one photo in the opposite direction including the surrounding area, and a relatively close up photo of exposed or suspended pipeline(s). Photos shall be attached to the G0 notification within SAP.

5. Before any work commences, the Pipeline Technician must ensure that that approval is obtained to access land for all restorative work in addition to creating an SAP M1 Maintenance Request Notification before the initial site visit.

6. The Field Work Planner shall be responsible for scheduling all work to be done by TransCanada personnel and equipment and for issuing minor contracts

7. Restorative erosion work may be in close proximity to buried facilities. A One-Call, where available, and stakeout to confirm the exact location of all buried facilities should be performed prior to commencing work. Excavation shall be undertaken with extreme care – refer to the Excavation Procedure.

8. The work shall be carried out only under the direction of qualified company personnel. A company representative shall supervise all contractors employed by TransCanada at all times while work is being carried out.

9. Whenever insufficient cover (exposed pipe, or lack of cover) is discovered, a Pipeline Insufficient Cover Initial Inspection Form shall be completed by the Region and attached to the G0 notification within SAP. The GPS coordinates of the exposed pipe must be accurate and included in the Pipeline Insufficient Cover Initial Inspection Form.

10. Erosion control measure shall comply with all Company, environmental and governmental regulations. All work shall be consistent with the requirements as specified in the Company’s current Construction Specifications. Regional Environmental Contact should be consulted for all erosion-related work to ensure compliance with environmental programs. All necessary permits and work approvals from landowners and other parties must be obtained prior to any work commencing

11. Erosion control shall be undertaken only when consideration has been given to aesthetics, structural stability, functional use and adequacy of materials (whether inert or non-biodegradable materials are required), local fish and wildlife, environmental habitats and surface drainage. The landowners’ wishes regarding the current and possible future use of the land shall also be considered

12. Some situations may require a temporary solution until a permanent restoration may be undertaken. The Region shall make arrangements with the landowners to secure permission for any periodic monitoring of the temporary restoration.

13. In extreme cases, barriers and signs may be erected at the point of entry to the pipeline right-of-way in addition to the areas affected by erosion control measures. These signs would be of a temporary nature; however the signage used must be adequate to protect and forewarn the neighboring public, landowners, company employees and others of possible hazardous conditions that may exist during soil stabilization periods.

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 12 of 16

14. If required for damage prevention or public safety, fencing /barriers may be installed around areas of

exposed pipe or low depth of cover to restrict access to area. In general, exposed pipe that is in agricultural, cultivated, or high land use areas should be fenced off. If the exposed pipe is not at risk of mechanical damage (i.e. in a pond), fencing may not be required. Pipe Integrity can provide additional guidance if required.

15. Pipe Integrity - Technical Support, should be contacted if the integrity of the line is suspected to be compromised, or the potential to become compromised exists due to erosion of low depth of cover.

16. Within practical limits all work and vehicular travel shall be contained to the designated areas. Temporary barriers may be erected to restrict access during seeding and re-vegetation programs at the appropriate times.

17. Damage Prevention / Weather and Outside Force / Technical Support shall provide technical assistance to the Region(s) upon request.

18. Gas Control shall be notified prior to any work on exposed piping or facilities.

5.0 DOCUMENTATION/REPORTING REQUIREMENTS

1. The Company is required to maintain records of all construction or installation of facilities and of all excavation for the useful life of the pipeline, or for at least two years after a section of the pipeline has been duly abandoned

2. Land Department shall maintain records of all potential and existing crossings.

3. Areas with insufficient of cover, or erosional issues shall be identified in SAP with a G0 notification. See Issue Management Procedure for additional information on issue reporting.

4. Whenever pipe is exposed or has insufficient cover, a Pipeline Insufficient Cover Initial Inspection Form shall be completed and attached to the G0 SAP notification.

5. Unintended movement or abnormal loading by environmental causes, such as earthquake, landslide or flood that impairs the serviceability of the pipeline shall be reported to the appropriate regulating body (e.g. DOT, NEB, CRE etc.)

6. Photos of any erosional issues shall be attached to the SAP G0 notification

6.0 ACRONYMS AND DEFINITIONS

Acronym Description AER Alberta Energy Regulator

AMAOP Alternative Maximum Allowable Operating Pressure

CFR Code of Federal Regulations

CRE Comisión Reguladora de Energía (Regulatory Commission of Energy)

DOT Department of Transportation

EHSM Employee Health and Safety Management – Incident Tracking Tool

HDD Horizontal Directional Drilling

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 13 of 16

LMS Learning Management System

NEB National Energy Board

NGTL Nova Gas Transmission Limited

NOM NORMA Oficial Mexicana (Official Mexican Standard)

OQ Operator Qualifications

PHMSA Pipeline and Hazardous Materials Safety Administration

ROW Right Of Way

7.0 LATEST REVISION

Description of changes: Revision 04: 1) New document contact assigned. 2) Combined US, Canada and Mexico into one TOP document; thus, scope of document

has been changed as in Revision 03 scope was only US and Mexico. (Pipeline Right Of Way Procedures Canada (EDMS No. 003672613) to be retired with the implementation of this TOP.)

3) Added the following sentence to the Scope (Section 2.0) for clarification purposes: This procedure applies to both liquid and gas transmission pipelines located within US, Canada and Mexico.

4) With formatting, hazards, qualifications and special resources sections were added. 5) Added references to the Signage Catalogue and additional descriptions for the various

ROW signs available (Section 4.1) 6) Created section to clarify location requirements of signs at crossing as well as along

the ROW (Sections 4.1.1 and 4.1.2) 7) Included requirements to have signs placed at bends greater than 30 degrees and 10m

u/s and d/s of the bend where land use permits (Section 4.1.2, Figure 6) 8) Removed minimum cover requirements except where special permits exist. Original

Construction DOC included (Section 4.2) 9) Added Depth of Cover requirements for AMAOP Pipelines (Bison) (Section 4.2) 10) Added clause for insufficient cover (Section 4.2.2) with instructions on notification

process, as well as Work Flow and RACI information in Appendix A and Appendix B 11) Changed the title of Section 4.3 from Erosion Control to Insufficient Cover 12) References updated to include additional internal and external references 13) Updated requirements based on regulatory review 14) No EHSMs exist with respect to this document 15) No external or internal permits or certificates etc. required for this document 16) Updated formatting as required to match the current TOPs template 17) Impact Assessment Form in TOPs database has been completed for revision 04 18) Lines of Business are accurate 19) Regulatory section of TOPs database was reviewed for accuracy and any new or

outdated items. 20) LMS Read and Acknowledge Elements: 71008481 (US& Mexico) and 71008268

(Canada) combined into 71008481(US-MEX-CAN). 71008268 to be retired with associated ROW Procedures TOP – Canada (EDMS No. 003672613).

21) Document formatted to current TOPs Procedure template. 22) Reviewers included: Brad Watson, Gina O’Beirne, Roel Lancee, Barbara Rabis, Kurt

Smith, Karla Hernandez, Meera Kothari, Lawrence Jaskowiec, William Jimenez, Dave Saunders, Ashton Friesen, Bill Liu, Richard Pacholok, Ian Chisholm, Carl Hewitt, Mark Klassen, Lawrence Pachal, Brett Grandy, Terri Steeves, Shaun O’Neill, Dean Christman, Marilyn Wenzel, Bruce Huynh and Daniel Ho

Document Modification Form: EDMS No. 009238148 Note: Refer to the Document Modification form for further information regarding this

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedure Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 14 of 16

revision of the document.

Impact Assessment Summary: • What is the cost impact of implementing the modification? None o Will more or different resources be required? (e.g. additional personnel,

translation, additional hours, new tools) No • What risks are associated with making the change? None. What are the risks if the

change is not made? o Are appropriate stakeholders identified who can sign off on the risk

costs/liabilities? Yes • What are the costs if the modification(s) is not implemented? None • Is a communication plan required to notify stakeholders of the change? (e.g. email

communication, presentations, pamphlets). No • Will the change be fully implemented upon approval or implemented in stages? Yes • Will the change affect regulatory compliance? No • Other impacts specific to the equipment, location or processes affected by the

requested change. None

8.0 APPROVAL

Name – Position – Department Signature – Date

Document Owner

Shannon Phillips Damage Prevention Engineer Damage Prevention and Valves 2015/09/25

Management Approver

Gina O’Beirne Manager Damage Prevention and Valves 2015/09/28

Next Review Date: 2016/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedures Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 15 of 16

APPENDIX A: EROSION / INSUFFICIENT COVER ISSUE WORKFLOW

Next Review Date: 2015/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).

TRANSCANADA OPERATING PROCEDURE (PROCEDURE)

Title: Pipeline Right Of Way Procedures Revision: 04 Effective Date: 2015/10/05 Status: Issued Driver: Regulatory Page 16 of 16

APPENDIX B: RACI CHART – EROSION / INSUFFICIENT COVER WORKFLOW

Next Review Date: 2015/10/05 Approval Date: 2015/09/28 Prior to use, validate paper copies against the official version (Doc ID 003864106) in EDMS (General Library).