As a result of the August 9 order by the Environmental Hearing Board, horizontal directional drilling (HDD) activity has been temporarily stopped in some locations along the Dragonpipe (Mariner East 2), but it continues elsewhere. And there continue to be frac-outs (aka “inadvertent returns”, “spills”). In September, there were 11 of them at various points along the pipeline route, as reported here. And that doesn’t count punctured aquifers and well problems, which the DEP doesn’t report.

The geological assessments. The August 9 order requires Sunoco/ETP to do a detailed geological assessment of at least 63 drilling sites. These reports are to be placed on the DEP website, and the public has 14 calendar days to submit “comments”. You can find links to the reports here. So far, 7 of these reports have been posted, and 5 of them have received public comments.

One issue which the geologists filing these reports are required to address is whether there are better routes or drilling depths than those originally planned. Two of the reports (called “Wetland C-17 Crossing”, covering an HDD site in Cambria County; and “Wetland J-47 Crossing”, covering an HDD site in Dauphin and Lebanon Counties) recommend a much deeper and longer drill path, to avoid frac-outs in the looser rock nearer the surface. The others do not recommend any change.

No evaluations of better routes? Really? It irritates me to find that none of the reports takes seriously the possibility of a different pipeline route. In most cases, this is not because the selected route is shown to be the best one. The geologists filing these reports (paid for by Sunoco/ETP) assume that no alternative routes are “practical”, because they would require obtaining new easements and new environmental permits.

But one of the sections in the order of August 9 requires that “The Report shall…, as appropriate, propose modification of the design of the HDD or relocation of the pipeline based upon the results of its study for that location.” It appears that, in practice, the possibility of relocation is being ignored.

Is this a violation of the order? The lawyers will have to determine that. But in my view, it shows that Sunoco/ETP’s compliance with this part of the agreement is turning out to be a sham. They agreed to consider alternative routes, but they are not doing so.