We’ve already seen one old pipeline (now known as Mariner East 1) leak three times in its brief existence as an NGL carrier. (NGLs are so-called “natural gas liquids”, a byproduct of fracking for natural gas. There is a more detailed description here.) Now Sunoco, stymied by opposition to the Dragonpipe (Mariner East 2), has a plan to convert another old pipeline to NGL service, bypassing incomplete parts of the Dragonpipe. The direction of flow would be reversed and it would begin carrying high-pressure, highly-explosives NGLs.  But how safe is that pipeline? The answer is: not safe at all. We have to stop it, and there will be some suggestions for how to do that at the end of this blog post.

The proposed bypass pipeline is a 12-inch line built in 1937, officially known as the “12-inch Point Breeze – Montello Line”.   It was designed to carry refined products, such as gasoline and fuel oil, from Philadelphia’s Point Breeze refinery to the Reading area. If anything, it is actually more likely than ME1 to leak (as explained below); and because it is bigger, a leak would represent a worse threat to safety.

The PHMSA warning against repurposing. The first thing to point out is that the federal pipeline agency PHMSA (the Pipeline Hazardous Material Pipeline Safety Agency, part of the Department of Transportation) has explicitly issued a warning to pipeline companies against the process of reversing and repurposing pipelines, in exactly the way Sunoco says it is planning to do. The warning came too late for ME1, but it should be heeded now. (For a more complete description of that PHMSA warning, and a link to its text, see “Sunoco is doing exactly what federal regulators warned against”.)

PHMSA issued the warning because of accidents resulting from this type of pipeline repurposing. For this reason alone, Sunoco’s plan should not be permitted. But there are plenty of additional reasons.

Does pressure-testing make it OK? Sunoco will tell you that the 12-inch line will be safe because it was upgraded and pressure-tested last year, and no leaks showed up. There are several flaws in that argument. Let’s start with the factors that have changed since then.

Running water in the easement. Pipelines are supported by the earth beneath them, and if water is running alongside the pipelines underground, soil can be washed away and the pipelines can be undermined. We know that water has been emerging from the ground at the easement across from the Shoen Road drill site. It began many months ago, after the Shoen Road drill hit an aquifer and drained nearby wells.

Given that the drill path was in the same easement as both ME1 and the 12” pipe, and given that the water is emerging in that easement, it’s a good bet that the water is following one or both of those pipelines. Sunoco wants us to assume that they are not being undermined, but there is no way to know that. And if the pipeline were sagging and began to crack, it could have happened long after last year’s pressure test.

Earth movement at Lisa Drive. The map below shows the paths of ME1 and the 12-inch line in the vicinity of Lisa Drive, near Exton. This is the spot where drilling for the Dragonpipe triggered sinkholes.

As the map shows, both the ME1 and the 12” pipeline undergo a series of sharp turns when they pass under the Route 30 Bypass and the adjacent Amtrak tracks. The 12” pipeline in particular makes a sharp turn to the east (to the right on the map) and follows the tracks as far as Ship Road, whereas the ME1 continues southeast along Lisa Drive.


Lisa Drive pipeline details 7-11-18
In the vicinity of Lisa Drive, both the 12-inch pipeline and ME1 cross under the Amtrak right-of-way together. But then (as shown in this map from PHMSA) they split. The 12-inch pipeline, as it approaches the sinkhole area, turns sharply east.

The 12” pipeline makes its turn very close to the spot where one of the sinkholes formed. Was the pipeline damaged when the sinkholes formed? The sinkholes formed after the pressure testing was done, so that test provides no information. Sunoco wants us to assume it’s fine.

Corner damage? The worry is not just that the pipeline itself could be put under stress. In the case of the 12” pipeline, the fact that the ground movement is right at a sharp corner is also a cause for worry. Corners of old pipelines can have special problems.

In 2004 the Interstate Natural Gas Association of America commissioned a study of the failure of old pipelines. The study is about failures of the pipe itself in its natural setting, not damage caused by excavation strikes or other direct human intervention.

The report, called “Integrity Characteristics of Vintage Pipelines”, puts the causes of leaks into various categories, including welding problems and “coupling failures” at the point of attachment of two segments of pipe. It points out that the pipelines of the 1930s generally used either mechanical coupling or miter bends when turning corners.

Miter bends were constructed in the field by cutting the pipe at an angle and welding the cut sections together “to produce locally abrupt changes in direction”. Mechanical couplings were factory-made arcs of pipe that were clamped onto the ends of the two segments to make the turn. Mechanical couplings were phased out by around 1940; miter bends were used until they were “prohibited by many construction standards in the late 1940s and early 1950s.” However, a large number of pipelines using these methods still remain in the ground in the form of “vintage” pipelines.

Given its age, the 12-inch pipeline is likely to have either miter bends or mechanical couplings.

The report provides a series of flowcharts to determine whether or not a given pipeline or configuration is a cause for concern. In the case of both miter bends and mechanical couplings, the report poses two questions to be considered: is the pipeline braced against movement along its axis? Is the pipeline subject to earth movements? If the answers are “no” and “yes” respectively, the corner has potential for problems. And that is exactly the situation with the 12” pipeline at Lisa Drive. Of course, Sunoco wants us to assume that no damage has been done.

Earth movements continue. What makes matters worse is that the earth movements at Lisa Drive continue to this day, as Sunoco brings in daily cement-mixer truckloads of grout which it injects into the ground in an effort to stabilize ME1. We know that the earth continues to move, because (according to the plan Sunoco submitted to the PUC) it is by monitoring small changes in ground elevation that Sunoco plans to determine when sufficient grouting has occurred. Once the earth starts to bulge slightly, that will be a sign that grouting should stop. ME1 may possibly be stabilized by this procedure, but what is it doing to the 12” line? Sunoco wants us to assume there is no adverse effect.

No ME1-style testing? As part of Sunoco’s agreement to restart ME1 after the PUC shut it down in response to Senator Dinniman’s Emergency Petition, Sunoco had to do a variety of tests on ME1 and file reports on emergency response plans, leak-detection plans, geophysical testing, and reporting of internal procedures to detect violations of various kinds. Sunoco was also required to “create for the public an integrity management program, risk analysis, and other information required to warn and protect the public and to reduce the hazards to which the public may be subjected.”

Sunoco has not done these tests and this reporting for the 12-inch pipeline, even though its size and its configuration at Lisa Drive make it potentially even more dangerous than ME1. Sunoco wants us to assume the pipeline will be fine without going through those steps.

And how good was that pressure test anyway? We don’t know what pressures were involved in the tests that Sunoco conducted on the 12” line. Were they high enough to be valid for the elevated pressures in a line carrying NGLs?

Perhaps the answer to that question isn’t important, because the test did not even catch an incipient leak that occurred with the line carrying gasoline. This same pipeline, the 12-inch Point Breeze-Montello line, leaked gasoline into Darby Creek last month (June 2018). If Sunoco can’t prevent leaks in a line carrying low-pressure gasoline, how are we supposed to assume it will prevent leaks when the very same line carries high-pressure NGLs?

The danger to public safety is obvious, and Sunoco’s desperate plan needs to be stopped immediately.

Next steps. There are several things you should be doing to help keep this plan from being implemented.

  1. Write and call the Governor. He can stop this immediately, and in his oath of office he took responsibility for the safety of Pennsylvania’s citizens.
  2. Write and call your state representatives. They can put pressure on the Governor.
  3. Write to the PUC. Tell them to fulfill their responsibility to keep us safe. Contact Rosemary Chiavetta, Secretary. Phone: 717-772-7777. Snail mail: Secretary’s Bureau, Pennsylvania Public Utility Commission, Commonwealth Keystone Building, 2nd Floor, Room-N201, Harrisburg 17120.
  4. Also email Paul Metro, Manager of Gas Safety at the PUC: pmetro@puc.gov.
  5. Ask your local municipality to file as intervenors in Senator Dinniman’s case before the PUC. This will show the PUC that the issues in the case are not local to just one community.
  6. Ask your local municipality to file an Emergency Petition and a Formal Complaint with the PUC, stating that your safety is jeopardized. The Petition and Complaint that Dinniman filed are readily available public documents and can serve as a template for your municipality’s document, so this is not a difficult process.
  7. Get out and protest!