The DEP is accepting public comments on Sunoco’s new plan to resume drilling at Shoen Road. You can read the details of the plan here. Unfortunately, the plan is full of errors, misleading statements, and modified geological information, and it fails to correct the problems that occurred during the previous HDD drilling at this site. You have until May 20 to file comments with the DEP. Instructions for doing that are at the bottom of this post.

Areas of concern: still not addressed. A previous geotechnical review of this area, from February 2020, pinpointed three “areas of concern”. The review was conducted by Rettew, a Sunoco contractor. Two of the areas (“A” and “B”) are on the hillside above Shoen Road, and one area (“C”) is under the road itself. The areas were marked with green ovals in the aerial photos submitted with the report. They are areas that Rettew singled out because geological testing there suggested possible problems with karst (limestone) formations that could result in drilling problems, sinkholes, surface seeps, or aquifer damage. A total of four new geotechnical borings  were made in these areas of concern as Sunoco prepared its required “restart report”.

The  two new geological borings on Shoen Road itself in Area C where there was an earlier subsidence were only 30 feet deep, too shallow to hit bedrock and be conclusive. Neither boring encountered karst, but that should not be surprising, since the karst found in the area lies much deeper (60 and >130 feet, as determined by previous borings on the adjacent HDD 360 drill site. Still, in its new report, Rettew makes the baseless claim that the karst does not occur anywhere along the HDD path.

Perhaps even more disturbing: in the photos in its new report, Rettew simply moved the ovals representing “areas of concern” away from the HDD path. No explanation for this change is given. Did Rettew simply move the ovals marking the areas of concern in order to avoid having to investigate the potential problems there? The two new borings on the hillside to depths of only 28 and 11 feet were inconclusive and not even on the proposed 20” path. Instead of more borings to investigate the areas of geological concern, Rettew makes an erroneous claim that a septic system exists (where one never has) in an attempt to account for the geological anomalies.

Here are the two photos, from the two Rettew reports, showing the areas of concern in different locations.

The left-hand diagram is from the original Rettew report. The right-hand one is from the new “restart” report. Note how the “areas of concern” (green ovals) have been moved. A gray line marks the path proposed  for HDD drilling.

Here is a diagram showing how the areas of concern have been relocated.

This aerial photo shows the same information as the two above, showing how the area-of-concern ovals have been moved. (I have redrawn the areas of concern as accurately as possible, although they may deviate slightly from the photos above.) The original areas are shown in blue; the relocated ones are shown in yellow. Rettew provided no explanation for why they were moved. The green line is the path proposed for the HDD, and the red Xs are the locations of the two test borings.

In addition to the two boring locations shown here, Rettew cited several other borings for its claim that there is no karst. But those borings are from other parts of the route, far enough away to be totally irrelevant to this particular area.

What about the aquifer? The last time Sunoco drilled here, they hit an aquifer and massive quantities of ground water emerged at the drill site for months. At one point, Sunoco was trucking away a quarter of a million gallons every day. That could happen again, and yet, the restart report provides no indication that Sunoco has any plan to avoid this problem. Even if the private or public water supply is not impacted, millions of gallons of pristine groundwater is turned into industrial waste.

And the problems with the previous HDD were not confined to the drilling process. Sunoco attempted to grout the space around the previously-installed 16” pipeline, which they claimed would stop groundwater from flowing along the pipe and making its way to the surface. But new seeps (small springs) appeared on the hillside along the drilling route. These continue flowing to this day, and they suggest that drilling has opened new paths for the groundwater. Will more drilling create more seeps, impacting private property? Do the seeps indicate that water is flowing along the sides of the pipe that is already in that hillside, potentially undermining it? Sunoco has not investigated those issues, even though it has recognized that its drilling caused the seeps.

Here’s what needs to be done. The DEP is currently accepting public comments about the plan for drilling at Shoen Road, and we all need to file comments by the May 20 deadline.

In your comments, tell the DEP that it must insist that Sunoco submit a new plan that:

  • Addresses the original areas of concern, not the bogus ones in Sunoco’s new restart report
  • Includes adequate geotechnical testing, with boring that is actually along the HDD alignment and that is deep enough to draw legitimate conclusions
  • Will ensure the aquifer will not be hit again
  • Will prevent frack-outs from the drilling
  • Will prevent new seeps

Write to the DEP at this address:

Tell them not to issue a permit for HDD-360 (which Sunoco is now calling “Biddle Drive”) until these issues are resolved and the public has a chance to comment on Sunoco’s response.

While you’re at it, why not copy your elected officials? They need to know where you stand.

Time is of the essence: the deadline for you to submit comments is May 20, just three days from now.