Requirements of the January 3, 2018 Administrative Order

Here are the 21 things Sunoco was required to do by the Administrative Order that suspended construction on the Mariner East 2 pipeline.

1. Shut down pipeline installation activities.
2. Explain the non-HDD, non-conventional boring techniques it was using at some sites (these techniques were not covered by its permits).
3. Document all “wild trout stream” crossings, including photos before, after, and during installation.
4. Report all changes to pipeline installations that deviated from the permit that was filed.
5. Provide a list of drilling subcontractors, with contact information.
6. Provide a report of the factors involved in the many documented permit violations, and the steps to prevent recurrence.
7. Address complaints of damage to wells in Cumberland County and compensate the owners.
8. Provide a list of all activities not yet completed under DEP permits, including HDD and trenching.
9. Provide a detailed operations plan to ensure permit conditions will be followed.
10. Backfill all trenched areas.
11. Remove drills, reamers, and drill strings from bore holes where HDD was not permitted.
12. Abandon pilot holes that have been drilled in locations where HDD was not permitted.
13. Abandon the 16-inch drill hole at the Huntingdon County site. (This was a site where no HDD was permitted.)
14. Before any further HDD activity at the Huntingdon site, submit a reevaluation and get it approved by the DEP.
15. Provide as-built drawings of the “air bridge” at the Perry County site, and either remove the air bridge or modify it to make it safe—with plans to be sealed by a licensed Professional
    Engineer . This is the location where Sunoco was found to be using a bridge that had been closed because it was unsafe as the support for its own temporary bridge.
16. Complete a proper permit application for the bridge work, above.
17. Provide, within 10 days, any additional information or revisions that the DEP requests regarding anything in this Order.
18. No restart of construction is permitted until the DEP provides written approval.
19. Provide stabilization and maintenance of “disturbed areas” during shutdown period.
20. In cases where the HDD drill string is allowed to remain in the hole, the drill may be moved back and forth but no drilling may be done.
21. Immediately begin implementing the “HDD Inadvertent Return” plan attached to the Order.

According to the February 8 Consent Order, all of these items had been “adequately addressed.” The details are in the many Exhibits and Appendices of the Consent Order.