Comment 1-8-2020

Just before the holidays, Sunoco filed plans for three “major modifications” to its construction plans for the Dragonpipe (Mariner East pipeline system). The locations are:

  • Lisa Drive area, near Exton, Chester County
  • Meadow Creek Lane area, just north of the PA Turnpike near Marsh Creek Lake, Chester County
  • Riddlewood/Tunbridge Apartments area, Middletown Township, Delaware County

The plans are major changes to the ones Sunoco has previously submitted. They are ill-conceived and carelessly assembled. If pipeline construction proceeds according to these plans, there could be serious—possibly even disastrous—problems. It is very important to submit comments to the DEP questioning these plans and demanding a public hearing on each of them.

You have until January 28 to submit your comments. (The deadline was to be January 13, but I have received confirmation from the DEP that it has been extended.)

In this blog post, I will provide a general overview of each of the three plans and indicate some of their shortcomings. At the end of the post are instructions for how your comments can be submitted by email.

If you would like to read the full text of these plans, it is available on the Mariner East section of the DEP website. Scroll down to the heading “Addendums to Chapter 105, Water Obstruction and Encroachment Permits and Chapter 102, Erosion and Sediment Control (E&S) Permits” and you will find the links in the paragraphs that follow.

Direct pipe boring. Note that each of these plans includes the use of “direct pipe boring”, a new relative of HDD. Instead of drilling a hole and then pulling the pipe through it, direct pipe boring involves pushing the pipe directly through the earth, using a combination of a drilling head at the leading end of the pipe and a hydraulic hammering system at the back. Once the pipe emerges at the other side, the drilling head is removed and the installation is complete. It is unclear to me what strains this puts on the pipe and whether it has ever been used with highly-volatile liquids before.

Lisa Drive. (Formal name: Lisa Drive / HDD S3-0400.). As Dragonpipe Diary readers know well, Lisa Drive, near Exton, was the location of repeated sinkholes during the installation of the initial 16-inch pipe. Sunoco ended up buying out local homeowners whose yards were undermined. Now, for the 20-inch pipe, Sunoco plans to switch to mostly open-trench construction, plus a section of “direct pipe boring” under the Amtrak rails and the Exton bypass. The stretch covered by this plan runs from the Laborer’s training facility on Business Route 30 up to near Stonegate Court (just off Ship Road).

Here are some of the issues associated with Sunoco’s proposal for Lisa Drive:

  1. Digging through the grout. In its attempts to fix the sinkhole problems at Lisa Drive, Sunoco put dozens of cement-truck loads of grout (cement-like material) into the ground. The new plan calls for boring through part of that grout and trenching through the rest. There is no indication in the plan that Sunoco has considered the issues that this could present. Two other pipes (the 8-inch ME1, which is actively transporting highly-volatile liquids and the newly-installed 16-inch pipeline) are buried in that grout. When Sunoco digs or bores through it, what will that do to the pipes already in the ground? Will the process trigger more sinkholes? What will it do to the nearby 12-inch “workaround” pipeline (also active)? Given the history of the site, is “direct bore” (which involves hydraulic hammering to advance the drill) the right technology for this location? Sunoco has not even mentioned those issues as a possible problem. In fact, the plan’s section covering sinkholes does not even acknowledge that there have ever been sinkholes at Lisa Drive.
  2. Stability of the Amtrak rails. While this is not strictly speaking an environmental problem, the use of direct boring under the Amtrak rails raises questions about rail integrity. The direct-boring profile is much closer to the surface than the HDD used previously, and it involves hydraulic hammering (which HDD did not). And yet, the Amtrak rails were loosened and had to be repaired because of the HDD. Is there a danger of a derailment here because of boring under the rails? That would certainly be an environmental disaster (not to mention a potential catastrophe and major economic disruption—but the DEP does not consider those issues in its permitting.)
  3. Major new areas of land occupied. In this plan, Sunoco greatly expands the “temporary workspace” for the construction. This occurs at both ends of the stretch and along much of the area proposed for open trench. This is a recipe for runoff problems and disruption of the community. Many mature trees in those areas will be lost. Sunoco must be required to explain why all this space is necessary.
  4. Errors and regulatory violations. My friends at Clean Air Council point out that there are many discrepancies and errors in the Sunoco plan. Here are some of them:
    1. Surrounding pipelines aren’t correctly located. In different maps of the area shown in the plan, the local pipelines are shown in different locations. How can this pipeline be safely constructed when Sunoco provides conflicting locations for existing pipelines?
    2. How many pipelines? In Section E, Sunoco says “the project involves the installation of approximately two pipelines”. It needs to specify how many pipelines are involved.
    3. Company name? In Section L, the company is listed as “Energy Transfer LLC”, which is not its name.
    4. What location? The latitude and longitude given for the location is wrong.
    5. Planting of invasive species. The restoration plan incorrectly calls for reseeding with non-native and invasive species. Only native species are supposed to be used.

Turnpike/Meadow Creek Lane (formal name: PA Turnpike / HDD S3-0280). In attempting to drill under an arm of Marsh Creek Lake, Sunoco experienced “loss of circulation” problems (meaning that the drill hit underground “voids” where the drilling mud dispersed and the drill could not be controlled). They gave up on that portion of the route and are now planning a route along Meadow Creek Lane, just north of the PA Turnpike. The route crosses under the turnpike at both ends, using the direct-bore method. With the exception of boring under Styer Road, the balance of the construction is to be open trench.

Here are some of the issues associated with Sunoco’s “Turnpike” plan:

  1. Dealing with steep hillsides. In Beaver County, Sunoco’s Revolution pipeline crossed a steep hillside that later gave way, causing a major explosion. In Sunoco’s “Turnpike” plan, there are several places where the pipeline cuts across steep slopes. Sunoco provides only this guidance: “The contractor should exercise additional care in managing stormwater, seeps, and stockpiles. If the steep portion of the slope is disturbed, an engineer should evaluate if the slope should be backfilled and restored with horizontal lifts.” Given Sunoco’s history, the company should provide more engineering guidance and not leave hillside installation up to the contractor.
  2. Unsafe spacing of pipes. Sunoco proposes to bore under Styer Road, using two pipes in a single casing, a maximum of a few inches apart. That violates PHMSA regulations, which require at least 12 inches unless that spacing is impractical. At Styer Road, however, there is no apparent reason for this spacing. There is plenty of room for two bore holes, one for each pipe (which is what Sunoco is proposing for the bores under the turnpike). Sunoco needs to explain why it requires this technique for Styer Road.
  3. Why not in the Turnpike right-of-way? Sunoco has placed this pipeline through a residential area, which will entail unnecessary risk and disruption, including the clearing of forested areas. In other parts of the state, it has run Mariner East alongside the PA Turnpike, and it could do so here. At one point in the plans, Sunoco mentions “future growth requirements” for the turnpike, but does not explain what this means or what restrictions the turnpike authorities have placed on pipeline construction. This choice needs to be explained and justified.
  4. Errors, discrepancies, and violations. My friends at Clean Air Council point out a number of additional problems with this plan:
    1. Was the assessment of threat to endangered species accurate? It’s not clear whether the agencies looking at endangered species protection got the correct, up-to-date plans. If they got old plans, they wouldn’t have looked at the right areas.
    2. Why a “riparian buffer waiver”? Construction plans involving stream and wetland crossings are required to allow a “riparian buffer” which minimizes the work area at the crossing point. Sunoco claims a “riparian buffer waiver” for this plan where it crosses a stream, but the plan fails to justify that claim.
    3. What will Sunoco do with the water in its bore pits? Boring equipment requires a pit that must be kept dry with pumps. Where will that water go? Getting rid of water has been a serious problem at many other sites, and there is no “dewatering basin” shown in these plans. Sunoco needs to explain where the water will go.
    4. Missing survey information. The contractor Tetra Tech began a survey of “cultural resources” (archaeological sites, for example). Was it ever completed? What were the results? The plan doesn’t say.
    5. Uwchlan Township response missing. Sunoco sent a letter to Upper Uwchlan Township claiming this project was consistent with local law. What was the Township’s response? That needs to be stated here.
    6. Company name? In Section L, the company is identified as “Energy Transfer LLC”, but that is not its correct name.
    7. Planting of invasive species. The restoration plan incorrectly calls for reseeding with non-native and invasive species. Only native species are supposed to be used.

Riddlewood/Tunbridge (formal name: Middletown Township, Delaware County / HDD 0620)

This is the stretch from Riddlewood down to Tunbridge Apartments in Middletown, Delaware County. Sunoco tried to drill uphill from Tunbridge and ran into numerous problems. They eventually abandoned the pilot hole and decided to switch to open trench construction, plus a “direct pipe bore” under the train tracks.

Here are some of the issues associated with Sunoco’s new plan:

  1. How will Sunoco deal with the rock that stopped it last time? Although Sunoco had to abandon its previous HDD in this area because it ran into rock it couldn’t deal with, this issue is not mentioned in the new plan. Why does the company think the direct-bore approach will work better? Will it even be possible to dig a trench? Will blasting be required? These issues have environmental consequences and need to be explained.
  2. Where is this, anyway? The USGS “location map” in Attachment 1 shows an area of Chester County, not Delaware County. Other maps in the plan show the correct location. This needs to be corrected.
  3. Wetlands or not? Figure 3-2 of the Erosion and Sediment Pollution Control Plan (“NWI Wetlands Map”) does not show wetlands in the vicinity of Tunbridge Apartments. Figure 4-13, two pages later, does show a wetland area. How is this discrepancy explained?
  4. Stability of the rails. While this is not strictly speaking an environmental problem, the use of direct boring under the railroad tracks raises questions about rail integrity. The direct-boring profile is much closer to the surface than the HDD used previously, and it involves hydraulic hammering (which HDD did not). And yet, the much deeper HDD loosened the Amtrak rails at Lisa Drive in Chester County, and they had to be repaired. Is there a danger of a derailment here because of boring under the rails? That would certainly be an environmental disaster (not to mention a potential catastrophe and major economic disruption—but the DEP does not consider those issues in its permitting.)
  5. Additional errors and discrepancies. My friends at Clean Air Council have pointed out some other problems (once their analysis is complete, I will update this section):
    1. In the Erosion and Sediment plan sheets, the streets have been incorrectly identified. There is apparent confusion between which one is Lenni Road, which is Pennell Road, and which is War Trophy Lane. This needs to be corrected.
    2. Along War Trophy Lane, the same page shows incorrect property boundaries, leading to incorrect boundaries for the “limit of disturbance”. This needs to be corrected.

Please submit a comment—here’s how. You can comment on one or more of the “major modification” plans described above. In fact, I encourage you to comment on all three. If you do, please submit three separate email comments, because the DEP will collect them according to which plan they relate to.

You’ll need to be clear about which of the plans your email is about. I suggest you give the formal name of the site in in the “subject” field of your email, something like this:

“Comment concerning Major Modification for Lisa Drive / HDD S3-0400”, or

“Comment concerning Major Modification for PA Turnpike / HDD S3-0280”, or

“Comment concerning Major Modification for Middletown Township, Delaware County / HDD 0620”

Be sure to emphasize that each of these is a major change. Make sure each comment calls for a hearing with public participation. Residents need a chance to be heard, and this is something the DEP can easily arrange.

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

Make sure to get your comments in by the January 28 deadline.

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