flood of paper (Annette 2-28-18)
Illustration credit: Annette Raimondi Murray

Now that construction is resuming on the Dragonpipe (Mariner East 2 pipeline) after the January suspension, we will start to see Sunoco filing more of the reports required by the August 9 settlement, as well as the public comments on those reports and the response by the DEP (Department of Environmental Protection) itself.

I have been reading through the DEP’s latest response to Sunoco’s report on its plans for horizontal directional drilling (HDD) between the Andover subdivision at Routes 352 and 926 and the intersection of 352 and Route 3. The most striking thing about it is how long and thorough the DEP response is.

Most DEP responses (and I have read a dozen or more) are short (typically 1-2 pages). They generally ask for things that Sunoco can easily do, like correcting an error in the submitted report or explaining a procedure in more detail.

Not this time. This time, the response is 7 pages containing 23 detailed questions. Some of them make serious demands on Sunoco. To me, this response represents a shift in the way the DEP is handling the Dragonpipe. It looks like they intend to try to hold Sunoco much more accountable for its practices, which have often been slipshod.

Here are a few quotes about the effect on wells, to give you a flavor:

Sunoco’s Report states that the HDD “could affect individual well use during active drilling for wells located within 150 linear ft.” Sunoco needs to explain why it focuses only on wells located within 150’, and must address whether other water supplies outside of 150’ could be affected…

Sunoco has the option to enter into written agreements with all private water supply owners whose water supplies may be impacted by this Drill, regardless of their location from the Drill…. In the alternative … it must provide a discussion of actions to be taken by Sunoco to prevent water supply impacts from occurring. Sunoco needs to demonstrate how, in the absence of the agreements described above, Sunoco will avoid impacts to all water supplies….

The Report discusses potential changes in water quality, but also needs to discuss potential changes to water quantity, as the potential exist for the HDD bore to adversely impact the yield of private water supply wells.

There are several requests for better information about geology: about geological fractures that cross the drill path (where water might easily travel), about the local bedrock, about issues steering the HDD drill in this area, and about actions to be taken if voids (rock-free areas) are encountered by the drill.

There are also several questions about the drilling techniques to be used, the content of the drilling mud, the potential issues with grouting, and the way that information about geology will be coordinated with the drilling. The DEP states that the test wells (borings) in the area are not close enough to each other (and not close enough to the drill path) to provide the needed information about the geology, and it calls for a new geophysical survey.

Finally, there are questions about how frac-outs will be avoided and what will happen if one occurs.

Some parts of the response only require Sunoco to clarify a procedure or state a policy. But in a number of cases, substantial fieldwork and contact with the local landowners is required.

Will this tougher line really change how Sunoco behaves? Will Sunoco actually do what the DEP is requiring of them? That remains to be seen.