In much of Delaware and Chester county, Sunoco construction sites have been strangely quiet the last few weeks. That seemed to conflict with Sunoco’s promise, on its last investor call, to have the Dragonpipe (Mariner East 2 pipeline) up and running in the third quarter of this year.

Now, we know why things have been quiet. Instead of finishing the Dragonpipe on an aggressive schedule, Sunoco’s current plan is to push its highly-explosive “natural gas liquids” (NGLS) through an old 12” pipe that follows approximately the same route. Our understanding is that the pipe is not currently in use and was most recently used to send diesel fuel from a refinery in Philadelphia to central Pennsylvania. It is not clear how old it is, but it may date back to the 1930s, like the pipe now known as Mariner East 1.

There is very little information about this plan available to the public. The best source for now is the excellent July 3 report from StateImpact.

Sunoco has been quietly informing municipalities along the route of its new plan. It has been telling them that no new permits or hearings are required for restarting the 12” pipeline, reversing its flow, and filling it with a completely different product. The company says that a 60-day notice to PHMSA (the federal Pipeline Hazardous Materials Safety Administration)—or, in some versions of the story, to the PA PUC (Public Utility Commission)— is all that is necessary, since the pipeline is still being used for “petroleum products”.

A Dragonpipe bypass route? The old pipeline would be connected to the completed stretches of the Dragonpipe at unspecified locations, in order to bypass the parts that are not yet complete. Construction site activities suggest that one such connection point may be the valve station behind Glenwood Elementary School in Middletown, Delaware County. Another may be at a location at Little Conestoga Road, near Marsh Creek State Park in northern Chester County, where there is also activity.

If those locations are the only ones, that means the plan would be for the NGLs to be pumped through the Dragonpipe from western PA to Conestoga Road, where they would switch to the old 12” line down to Glenwood. From there, they would go back to the Dragonpipe to finish the trip to Marcus Hook.

To make that work, Sunoco would have to complete work on at least one of the two pipelines (20” or 16”) all the way from western PA to Conestoga Road, and they would have to finish the stretch from Glenwood to Marcus Hook. The rest of the Dragonpipe work could be left for later. That scenario would explain why Sunoco has been feverishly trying to finish the HDD work at Tunbridge Apartments (which is between Glenwood and Marcus Hook). Stepped-up work west of our area would explain why there are suddenly a rash of new Notices of Violation (4 in the last week of June alone) for frac-outs in Blair, Westmoreland, Cambria, Berks, Lebanon, and Washington counties (in central and western PA).

The current lack of construction activity in most of the rest of Delaware and Chester counties is also consistent with that scenario.

Implications of this plan. For Sunoco, this plan means a chance to more than double the volume of NGLs currently carried by Mariner East 1, although the volume would still be far short of the intended volume of the Dragonpipe. Sunoco is desperate for some good news about the Dragonpipe, which has been falling farther and farther behind schedule with each quarterly investor report. And the company’s massive debt burden requires it to find more sources of revenue soon.

For residents of Chester and Delaware counties, it means new risks associated with an old pipeline being pressed into service for product it was not designed to carry. For those living and working in the area being bypassed, it means a temporary respite from the noise, dust, and aquifer damage caused by Dragonpipe construction—combined with uncertainty about the safety of the bypass pipeline.

We have heard from municipal representatives that Sunoco is saying “all HDD plans are under review”, and many may ultimately be switched to open cut. If that is true, many months of permit applications and hearings lie ahead, during which construction at those sites will be halted.

Many questions remain. Sunoco has made no public statements, so we know only what we have heard from municipal representatives that have spoken to Sunoco, and from the StateImpact reporting. Here are some of the questions we have:

  • Exactly where does the 12” pipe run? Does it follow the same easements as the Dragonpipe?
  • What are the existing emergency-response plans for a leak on that pipeline? Have they been updated to account for the presences of NGLs?
  • When was the pipeline tested to see if it can handle the very high pressures required for transporting NGLs?
  • Have there previously been leaks along this pipeline? (It looks as if the answer is “yes”; details need to be known.)
  • Isn’t there a formal process for “abandonment” and “resumption of service” for a pipeline like this? Has that process occurred?

You will doubtless think of other questions that need to be answered. Talk to your elected officials about them, and make sure they are working on a response to Sunoco’s plan!