appalachian drive 3-31-19
For pipeline construction at this stretch of Appalachian Drive, in Cumberland County near Carlisle, Sunoco has submitted a flawed and dangerous proposal. The area is densely populated and has had sinkhole problems previously.

I tend to write about Sunoco’s problems in Delaware and Chester Counties, where I am familiar with the issues and the route. But there are many other places across the state where Sunoco’s work has been equally sloppy. One example is the Appalachian Drive area of Cumberland County, just north of Carlisle.

Sunoco recently filed a revised plan with the DEP for its failed HDD attempt at that location. (Although the governor announced a halt in the issuing of DEP permits for Sunoco, the DEP has continued to accept permit applications, review them, and solicit public comment. The application for this particular permit revision is here.) The new plan for this location is seriously flawed, as described below. No matter where you live, you can help fix this problem by contacting the DEP about it (details on how are at the end). Let them know you’re paying attention!

In its previous attempt at HDD in this location, Sunoco caused sinkholes (one of which exposed a gas main operated by UGI), damaged at least one well (probably more), and caused severe vibration that damaged surrounding homes. In the end, for reasons which Sunoco has never really disclosed, the HDD was abandoned. Now, they want to try again with a slightly different plan.

The plan is incomplete as submitted. As Clean Air Council points out in its comment on the plan, the DEP should refuse to accept this plan. In fact, the DEP should have rejected the plan immediately, because it is incomplete. Although a hydrogeologic study was required to be part of the geophysical survey in the submission (and the study may actually have been done), it is missing from the submission. That means anyone wanting to do a serious review of the plan cannot.

The plan does not fix the problems of the previous attempt. The new plan proposes a combination of trenching and “guided bore” (a “mini-HDD” system), but contains no information to indicate that this would be in any respect an improvement over the previous HDD-based attempt. In fact, since it will involve a shallow bore under a railroad track at a depth “between 10 and 25 feet”, it is arguably less safe. The possibility of a sinkhole under the tracks is an invitation to disaster, but this possibility is not considered in the new plan. In the previous HDD plan, Sunoco claimed that it had chosen “the best substrates” (i.e. the most stable rock) for its drill path. Does that mean the rock to be bored this time is worse? Did Sunoco even evaluate the rock it proposes to bore through? Apparently not. This is a karst area, where sinkholes are common, and sinkholes occurred on the last attempt.

What about the wells? Sunoco admits that at least one well was contaminated last time, and it also admits that it did not gather any information about the depth of the wells in the area or the depth to their water level. There is nothing in this new plan that suggests they have considered how to avoid well contamination problems this time.

The area is densely populated. This stretch of the right-of-way runs between two trailer parks, one with 92 lots, and one with 236 lots. The trailers are closely spaced. This means that even a small NGL leak could threaten hundreds of people. Could the danger of a rupture of the exposed UGI gas main have been the reason the previous HDD was abandoned? We don’t know, but a natural gas rupture in the middle of such a concentrated area of housing would also be a major disaster. What steps has Sunoco taken to avoid that possibility this time? What kind of emergency planning has been done?

Here’s how you can help. All of this should sound ominously familiar to anyone who has been following the problems at Lisa Drive near Exton, and the DEP needs to hear from you. Although the official comment period for this plan as listed in the “HDD Reevaluation” table on the DEP website ended March 19, the DEP should not allow Sunoco to get away with this.

Please write to the DEP at this email address:

Mention the fact that the plan Sunoco submitted for the “Appalachian Drive HDD” location was incomplete and inadequate. Ask the DEP to insist on a proper application from Sunoco, and then restart the public comment period.

It’s bad enough that the DEP is continuing to process these applications during a period when they are supposedly “on hold”. Under the circumstances, for the DEP not to reject an application with an important section completely missing adds insult to injury. Let the DEP know that this is not acceptable.