A lot is happening but this request must not be allowed to fall through the cracks. As many people as possible need to file comments about Sunoco’s plans for drilling on Valley Road. Instructions for how to do so are at the end of this post.

Sunoco has filed a response to the questions from the Department of Environmental Protection (DEP) about the horizontal directional drilling (HDD) plans for the southern part of Valley Road. These are the questions following up the initial public comment period for that HDD site, and the new 5-day comment period ends tomorrow (Saturday, May 26).

If you read the DEP’s questions, you will see that the DEP has gotten much more demanding in its questioning of Sunoco. There are 30 specific questions posed, some with several sub-parts. In response, Sunoco has become more defiant in its answers, basically challenging DEP’s expertise in asking the questions. In essence, Sunoco is saying “we are the HDD experts, not you, so stop trying to tell us what to do”.

You may want look at Sunoco’s response, at least briefly. (It is 19 pages plus attachments, but a good bit of that is just reiterating the DEP questions.) As you draft your comments, I suggest that you focus on the issue of whether it is appropriate for Sunoco to ignore DEP requests, as it does in many instances in this document.

It is most useful if you put your comments into your own words.

Here are some examples:

On page 1, the DEP says that “surface geophysics should be employed to provide evidence of the top of bedrock along the whole run…”. Sunoco refuses to do these tests, saying “the five geotechnical bores provide more than adequate information.” (To clarify: “geophysics” involves using techniques such as sound waves to map underground structures; “geotechnical bores” just means rock core samples from a vertical drill.) You might want to say something like: “The DEP should insist on a geophysical study; core samples from a few sites are not enough.”

On page 3, the DEP requests a plan for monitoring wells along the HDD. The response is that Sunoco “implements regular monitoring of adjacent water wells”, but it does not say what “regular” means nor does it agree to provide a plan. You might want to ask the DEP to insist on a plan with an associated schedule.

On page 4, the DEP says that “specific points of potential weak bedrock and soils were not individually identified. This should be done.” Sunoco responds that this is not needed because the driller will know when weak spots are encountered by monitoring the pressure of the drilling mud. You could say that potential weak spots should be identified in advance.

On page 6, the DEP asks Sunoco to address the possibility of IRs (“inadvertent returns”, or frac-outs) where there is weak soil. Sunoco talks about the possibility that drillers could use minimum drilling-mud pressure in such locations, but does not commit to requiring drillers to do that. You could tell the DEP to insist that Sunoco require its drillers to minimize drilling-mud pressure in areas of weak soil.

On page 7, the DEP asks how Sunoco will deal with groundwater emerging at the HDD site if its grouting plan for plugging the HDD hole is inadequate. Sunoco responds that it has “not had a failure” of this kind on the ME2 project. But there was such a failure at the Shoen Road site last summer, and it has yet to be fixed. Sunoco grouted the bore hole and, while groundwater is not emerging through the bore hole, it is emerging on a property across the road. Sunoco needs a better answer, and you can tell the DEP to insist on one.

On page 8, the DEP asks Sunoco to notify the Department during critical drilling phases so that “DEP regional staff will be provided with adequate advance notice to allow DEP staff to be present” in case there is groundwater flowing back to the borehole. Sunoco refuses, saying only that it will provide the DEP with “advance notice of commencing all HDDs, project wide”. You can tell the DEP to insist on notification during critical phases of drilling.

On page 11, the DEP says that, given the frac-out problems in the past, drilling contractors should be required to use a casing (i.e. a pipe liner) in the pilot hole at the entry and exit points. Sunoco refuses, saying that its HDD plan for this site doesn’t require it. You can suggest that the DEP insist on the use of a casing.

On page 13, the DEP again requests geophysical studies to determine where the bedrock is, to identify soft soils, and to find rock fractures. Sunoco refuses, saying these studies “will provide no functional data” at this location. You can ask the DEP to insist on geophysical studies.

Also on page 13, the DEP asks Sunoco for “well depths, casing depths, and water-level depths (based on a water-level survey)” on the cross-section diagrams of the HDD. Sunoco claims to have done this, but no water-level survey was apparently done. As far as I can see, the water levels shown in the cross sections are only those encountered in Sunoco’s five boreholes, not in local wells. And in the list of 32 private wells given in Attachment 1, 30 of them have a water level of “unknown”. You can ask the DEP to insist on a proper survey of water levels in local wells.

On page 16, the DEP recommends that Sunoco use 20 feet of grouting (instead of the 15 feet in its plan) when plugging to stop groundwater flow. Sunoco’s response is a curt “[Sunoco] appreciates the Department’s recommendation.” It will clearly be ignored. You can ask the DEP to insist that 20 feet of grouting be used in this situation.

Overall, this document suggests to me that Sunoco has decided it is fine to ignore the DEP’s requests. The company is determined to do as it pleases.

We need to provide the DEP with ammunition to fight back. Tell the DEP to insist that Sunoco comply with its requests.  The DEP has the power to revoke Sunoco’s drilling permits, and now is the time to begin applying that leverage.

How to submit your comments. Let the DEP know what you think, at this address:

ra-eppipelines@pa.gov

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 (kurbanowicz@cleanair.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.