Sunoco has filed a plan to drill a second tunnel to run a pipeline from Judy Way in Aston to the Delaware County Field and Stream gun club in Middletown, south of the Linvilla orchard. This is the second phase of Dragonpipe (Mariner East pipeline) construction at this location. In the first phase, a 16-inch pipeline was installed. That pipeline is now in operation, a part of the cobbled-together “Frankenpipe” that Sunoco started up at the end of 2018.

Sunoco now plans to install a second pipeline, 20 inches in diameter, along the same route. Once again, HDD (horizontal directional drilling) is to be used. There are to be two drill sites, one at each end of the run, that will meet each other deep under Chester Creek.

The full text of Sunoco’s plan is here.

This plan has problems. The previous HDD, in 2017, resulted in a series of frac-outs (the first ones experienced in this part of Pennsylvania), and there is good reason to believe that they will happen again unless the route is altered. Also, the location of the drill site at the southeastern end is itself a problem.

The Department of Environmental Protection is asking for public feedback on this plan, and the deadline for comments is June 20. I urge you to submit comments. Instructions for doing so are at the end of this post.

Here are two of the key areas to comment on. There are additional details about each issue below.

  • This project follows the same route as the previously-installed 16-inch pipeline. Because frac-outs happened here before, they are likely to happen again. The route should be altered to avoid this.
  • The location of the drill site at the southeastern end of this stretch is problematic because it is next to the Elwyn sheltered workshop on Judy Way. If a leak and fire happened there, it would block the only route in or out and trap the Elwyn clients. The drill site should be moved.

Use your own words, but please submit a comment!

Frac-out risk. Given that the proposed route for the 20-inch HDD is essentially the same as that for the previous 16-inch one, except a bit deeper, we can probably expect frac-outs in similar locations.

When the 16-inch pilot hole was drilled, there were frac-outs right in Chester Creek, as well as in the yards of nearby homes. These occurred near the spot where a sewer line crosses the creek, and they were blamed on two factors that weakened the rock at that location. One is a geological fracture zone there, and the other is fracturing created by blasting when the sewer line was put in. These same factors could easily lead to frac-outs this time around.

Alternative route for HDD? Sunoco should be required to evaluate the options for a somewhat different underground path for its HDD. It is required by its settlement with the PUC to consider alternative routes, but in its proposal document, it does not. The company simply refers back to the route analysis it did when it originally proposed this pipeline.

But that analysis was done prior to the frac-outs that plagued the 16-inch drilling process. No analysis of alternatives has been done that takes the history of frac-outs into account. Sunoco must be required to do that now. Can a route be identified that crosses under the creek in a location that it not a known fracture zone? Wouldn’t that be a better alternative to try?

In its proposal, Sunoco argues that routes outside its existing easements (which it refers to as “greenfield” routes) would be environmentally harmful. That could be the case for surface trenching and boring operations, but HDD is used precisely because it generally does not affect the ground surface. It is true that Sunoco would have to secure new easements if the underground route of the HDD is changed, but the DEP should insist that the company at least explores such an alternative and explains why its current plan is better.

Judy Way drill site 6-19-19
View looking north from the Judy Way drill site. (Base image from Google.)

Elwyn clients trapped. The location of the southeast drill site needs to be changed, but for a different reason. It is on Judy Way in Aston, adjacent to an Elwyn “sheltered workshop” where dozens of adults with mental limitations go every day. Last years Citizens’ Risk Assessment showed us that the point where HDDs enter the ground is exceptionally dangerous, because underground leaks are likely to emerge there.

In the case of the Judy Way drill site, it gets even worse: a fire at that site would block the only road into or out of the Elwyn facility, leaving no evacuation route and no way for emergency responders to get in and assist those threatened by the fire.

Sunoco needs to shift the location of the drill site by a few hundred feet in one direction or the other to remove this threat to our most vulnerable residents.

Let the DEP know what you think! This plan could cause more frac-outs in Chester Creek and the surrounding neighborhoods. It could endanger our most vulnerable residents. Minor changes to the plan could help to prevent these outcomes.

Please submit your comments immediately. Feel free to make use of the information in this blog post in the comments you submit. But it is more effective if you use your own wording rather than simply copying mine. The DEP needs to hear from you!

Email your comments to: Ra-eppipelines@pa.gov

Mention the ID number for this section of the pipeline, which is S3-0631. The deadline is this Thursday, June 20 (that’s tomorrow, if you’re reading this on Wednesday).

While you’re at it, why not copy your local state representative and senator? They need to hear your opinion too.

Note to Brookhaven residents only: does Sunoco have clearance to drill near the swim club? This is a separate issue from comments to the DEP, but something that the public needs to be aware of. When frac-outs occurred along Chester Creek Road in Brookhaven during the last HDD on this stretch, local residents (and township officials) were taken by surprise. Sunoco apparently had no easements for the properties where the frac-outs occurred, just upstream from the Brookhaven Swim Club. Sunoco’s response was that the drill was actually under Aston (where it did have easements) at the time of the frac-outs, but the drilling mud migrated laterally through a fracture and surfaced in Brookhaven.

This time, though, there is no question that Sunoco plans to drill under Brookhaven at the previous frac-out location. At least twice in the current plan, Sunoco states that the drill path with pass under Chester Creek east of Dutton Mill Road. Since Chester Creek is the boundary between Aston and Brookhaven in that area, the drill will cross into Brookhaven. Has Sunoco secured the necessary easements? It seems doubtful, if they didn’t have them previously. Brookhaven residents should check with their local officials to determine if Sunoco has the right to drill there.