I hate to interrupt your holiday, but this is important.
The DEP has decided to call for public comments on the construction of a segment of the Dragonpipe (Mariner East pipeline system) in Chester County, and the deadline is December 31. This blog post will provide information about the plan, suggest some things about it that need to be improved, and give you instructions for sending in your comments.
The plan. Sunoco wants to use horizontal directional drilling (HDD) to put a stretch of 20-inch pipe under Boot Road, starting next to the Goshen firehouse at Route 202 and extending to the Corner Park Apartments, where Ship Road splits off from Boot Road, a distance of almost a mile.
The companion 16-inch pipeline was already installed along that route. In fact, that’s why there is a call for public comments now: in a 2017 settlement, the DEP agreed to solicit public comments on Sunoco’s HDD plans in any location where there had previously been an inadvertent return of drilling mud (“frack-out”) during a previous pipeline installation. There were two frack-outs when the 16-inch pipe was installed; hence this comment period.
You can read Sunoco’s plan for this stretch on the DEP website. I will summarize a few of the issues I have with it here. It is important to comment, even if you don’t plow through the plan itself (which, with its appendices, is over 100 pages). We need to let the DEP know that we are worried about this work.
Why now? My first concern with this public comment period is the timing. If you actually want comments from the public you do not choose a comment period (December 17-31) that includes Hanukah, Christmas, and New Years Eve.
Tell the DEP that the comment period was inappropriate. Insist that it must be extended so that more people can comment.
Will Boot Road be damaged again? Will mud be released into storm drains and wetlands? During the fall, there have been multiple instances of problems along the adjoining stretch of Boot Road, due to HDD work in the Wilson Drive area. Parts of the roadway have sunk, and there have been frack-outs, with drilling mud emerging in the street and, in some cases, flowing into the storm drains. Will the same thing happen with this stretch of Boot Road?
The report contains a section called “Adjacent Features Analysis”, but it is limited to considering possible effects on wells along the segment. There is nothing about the causes of the previous Boot Road problems and how something similar will be prevented.
The report acknowledges that frack-outs may occur again with this HDD, as they did with the 16-inch HDD along the same route, but it downplays them. “Based on the information reviewed by the Geotechnical Evaluation Leader, Professional Geologists, Professional Engineers, and HDD specialists,” it concludes, “the HDD Reevaluation Team’s opinion is that the proposed HDD design and implementation of the management measures contained within the re-evaluation report will minimize the risk of IRs.”
And while the report acknowledges the likelihood of groundwater flowback, causing groundwater to emerge from one end or the other of the HDD, it does not consider the potential for a serious problem that could cause flows into storm drains, or into the wetland near the northwest end of the HDD.
Tell the DEP that it needs to require Sunoco to specify how it will prevent spillage into the storm sewers and wetlands, and how it will prevent damage to the roadway.
Why these endpoints? One end of the HDD is adjacent to the Goshen firehouse. The other is within 50 feet of the Corner Park Apartments. Once the pipeline is operational, the endpoints of an HDD are locations of increased risk of a release of highly-volatile explosive gas. It is obviously unwise to have these next to a firehouse and an apartment building.
Tell the DEP that Sunoco must justify its choice of these locations for its HDD endpoints.
What about the loss-of-circulation problem? When the 16-inch pipeline was installed, there was a location (about 300 feet from the northeast end of the HDD) where there was a “loss of circulation” (LOC) of the drilling mud. This means that the drill hit a void in the rock into which drilling mud flowed uncontrollably, causing the drill bit to stop turning. Eventually, it was necessary to resume drilling from the opposite end of the HDD.
Where did that mud go? Is it polluting an aquifer? Will the same problem happen again with this HDD? The report is totally silent on these issues.
It seems likely that problem will recur: if you look at the geotechnical studies in the report, you can see that there is a built-in geological reason to expect problems. On page 21, there is a map of the geological formations in the area, and the boundary between the “Peters Creek Tectonite (Octoraro Formation)” and the “Glenarm Wissahickon Formation” occurs at approximately the location of the LOC. Fractures and voids commonly occur at points where different formations meet.
The “Multichannel Analysis of Surface Waves” (MASW) chart of the HDD path (p. 104) shows an obvious gap in the rock at about 300 feet from the northwest end. There is a subtler, but still evident, gap between areas of hardest rock at about 300 feet in the “Seismic Refraction Tomography” image of the HDD path (p 102). These are all clues suggesting an underground fissure that will have to be dealt with.
Tell the DEP to require Sunoco to specify how it will deal with this problem, if it is encountered, and how it will ensure that an aquifer is not being contaminated with drilling mud.
Is the report’s author qualified? The report was signed (and apparently written) by Larry J. Gremminger. His title is “Vice President – Environmental Geotechnical Evaluation Leader”. His only credential is “CWB” (Certified Wildlife Biologist).
This is an engineering report. Tell the DEP that it must require Sunoco to provide a report from a licensed engineer, not a wildlife biologist.
Please submit a comment. I urge you to submit your comments to the DEP. It just takes an email. Sunoco’s plan has the potential to damage the environment and put people’s lives at risk. Tell the DEP that Sunoco should be required to do better.
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: firstname.lastname@example.org
Mention the ID number for this section of the pipeline, which is PA-CH-0290.0000-RD. The deadline is Tuesday, December 31.
While you’re at it, why not copy your local state representative, state senator, and Governor Wolf? They need to hear your opinion too.