The Department of Environmental Protection (DEP) is accepting public comments on Sunoco’s latest plan for horizontal drilling (HDD) in Delaware County. The current plan covers a section of the Dragonpipe (Mariner East 2) that runs along Valley Road from just north of Gradyville Road to just south of Sycamore Mills Road.
Among Sunoco’s bad plans for many areas, this particular plan stands out as especially bad. I will lay out the reasons in this post. Please tell the DEP how bad this is! You will find instructions for commenting at the end of this post. Give the DEP reasons to say “no”. I suggest you summarize the information in your own words: that seems more likely to influence the DEP than simply cutting and pasting. The deadline for comments is this Friday, March 18.
Tell the DEP Sunoco must consider alternative routes. Sunoco was required (by the August 9, 2017 agreement) to consider alternative routes for many sections of the pipeline. They never have. In every report they file (including the one for this site) they claim that there is no real alternative.
In the case of this particular section, the flaws in the proposed route are really outrageous, compared with almost any conceivable alternative. There is far more open space to either side of the selected route, where the environmental consequences of construction, or the risks from a rupture, would be far less.
Instead, Sunoco has chosen a route that runs right down Valley Road. This is a bad route for three important reasons: most of the homes in the area are on Valley Road (so the pipeline will be within a few feet of many of them); similarly, it endangers most of the wells in the area (which are near those homes); and it sends the drill directly through an area where the ground is known to be polluted with the chemical MBTE (see below), thus spreading the pollution throughout the area.
The DEP needs to insist that Sunoco prove why its proposed route is preferable alternatives. The real reason Sunoco favors this route is just its own convenience: it already has an easement there. That is not a sufficient reason.
Tell the DEP Sunoco must stop spreading MTBE pollution. In 2015, a gasoline pipeline leak was discovered in the vicinity of Valley Road and Gradyville Road. No one knows how long it had been leaking. One consequence was the appearance of a gasoline additive, MTBE, in some local wells. MTBE is water soluble, so MTBE that is present in a local source can travel through an aquifer and affect other areas. Even at low concentrations, it imparts a foul taste to the water. It’s not clear what other health consequences there may be.
If Sunoco goes ahead with its drilling plan, the drill will pass through the area where the ground is polluted with MTBE. Not only will the passage of the drill spread this pollutant, but the nature of HDD drilling will spread it even more effectively. In HDD drilling, the drilling mud used as a lubricant is forced under pressure down the drill pipe to the drill bit, and it returns back to the drill along the outside of the drill pipe (unless, of course, it finds another route to the surface, causing a “frac-out”). This circulation of the drilling mud (down to the bit and then back to the drill site) ensures that any pollution in the ground that the drill passes through will be spread all along the drill’s path.
Sunoco should be well aware of this pollution problem, since the gasoline pipeline that leaked was one of theirs, and they maintain water-monitoring wells in the area as a result. Incredibly, though, there is not a single mention of the MTBE pollution problem in their detailed 70-page plan for drilling.
There is, however, an acknowledgement of the incident in the attached report of GES, the geology firm that did the geological analysis of this area. In that report, GES says: “On April 10, 2015, a release of petroleum (diesel, kerosene, and gasoline) was reported west of Valley Road near the Valley Road/Gradyville Road intersection. A pinhole leak was identified in the Sunoco Pipeline Limited Partnership (SPLP) 12-inch-diameter Point Breeze to Montello Pipelines, which was temporarily repaired on April 11, 2015, then permanently repaired in July, 2017….. It is GES’ understanding that this data has been incorporated as part of the HDD construction preparation and response planning activities.”
If the data has been incorporated in the plan, why is that never stated? And why is the pollutant MTBE never mentioned as a potential problem? What is Sunoco’s plan for dealing with the spread of MTBE and its possible flow into Chester Creek if Sunoco has flow-back problems (as it did in other drill sites)? The DEP needs to insist on answers.
Tell the DEP that giving everyone water buffaloes is not a solution. Sunoco’s plan makes it clear that wells in the area may well be drained or fouled by the drilling. The plan states: “It has been verified that 26 properties are located within 450 feet of the [drill path] with all but 3 properties served by residential wells. These wells are open cased at the same depth as the boring, which increases the risk of impact by drilling fluids.” In addition, the highly-fractured rock in the area means that hitting an aquifer with the drill is likely, and that water travels fairly freely throughout the area. So it is likely that a lot of wells will be affected.
According to the geology report, “If significant volumes of drilling fluids were lost, they will tend to migrate along secondary paths of porosity toward groundwater discharge points or residential wells.” In other words, the high-pressure drilling mud will follow any path it can, and some of those paths will lead to people’s wells.
And those three homeowners who are identified as being on public water? Local residents tell me that there is no public water available in the area. Sunoco’s identification of those three as being on public water is probably an error. If so, it doesn’t reflect well on their homeowner-contact process.
Since many wells are likely to be affected, Sunoco would like homeowners to sign up for alternative water sources—in this case, plastic barrels called “water buffaloes”. The DEP needs to make it clear to Sunoco that providing water buffaloes is not a solution for ruining people’s groundwater.
Tell the DEP that Sunoco needs a real solution for groundwater flow-back. Because the water table is shallow in this area, and because the drill will be located in a relatively low spot, groundwater is likely to come rushing back to the drill. As the geology report puts it, “If the HDD contacts a significant fracture network, it could produce quantities of flow back groundwater greater than can be recycled and re-used in the drilling process. Subsequently, a groundwater flow back containment system should be deployed at the drill site to manage excess groundwater discharge to land surface.” That’s what Sunoco failed to handle at both Shoen Road and Tunbridge Apartments. They drilled into aquifers with far more water than their systems could handle, resulting well draining and discharges into neighboring streams.
In this location, there is the additional issue of that overflow water containing petroleum and MTBE from the leak site. What indication is there that Sunoco will handle this location better than others in the past? How will Sunoco protect the nearby land and Chester Creek from pollution? The plan says only that the flow-back water will be monitored for sheens and smells. The DEP must require Sunoco to do better.
Tell the DEP that Sunoco must consider the risk of human injury or death. While the DEP’s primary mission is the preservation of the environment, it must also take seriously the risk that this pipeline poses to nearby residents if it becomes operational. A clean environment is essential to human health, and that is certainly critical; but its importance is secondary when human life itself is at stake. The DEP needs to make sure that this pipeline, if it is built, is constructed in a manner and in a location that minimizes its risk to people.
How to submit your comments. The DEP is soliciting public comments on Sunoco’s plans for this drilling plan until Friday, March 18. Let them know what you think, at this address:
Tell the DEP about the problems you see with these plans. Feel free to use the ideas listed above, but it is most effective if you put it in your own words.
To have greatest effect, it is important to send copies of your DEP comments to several other places:
- To the Clean Air Council, who needs your comments as ammunition in its fight against the pipeline. Send copies to Kathryn Urbanowicz (firstname.lastname@example.org)
- To Governor Wolf, who has the power to stop this pipeline if he wants to. You can use this contact form: https://www.governor.pa.gov/contact/
- Send copies of your comments to your state senator and representative too. They can help put pressure on the DEP, the PUC, and the governor.