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Delaware River Pipeline Relocation Project (Paulsboro)

Delaware River Pipeline Relocation Project – Paulsboro Natural Gas Pipeline Company, from Delaware County PA under the Delaware River to Paulsboro Refinery, NJ

The Paulsboro Natural Gas Pipeline Company (PNGPC) has proposed to build a pipeline under the Delaware River to connect the Paulsboro Refinery in Paulsboro, Gloucester County, New Jersey (the pipeline actually would surface in Greenwich Township) to a tie-in with an existing Spectra 16-inch diameter Pipeline in Tinicum Township, Delaware County, PA (adjacent to the Philadelphia International Airport).

The project is replacing an existing natural gas pipeline that was damaged by the Army Corps of Engineers’ Delaware River Deepening of the navigation channel and had to be closed off.  The new pipeline would be constructed using HDD under the Delaware River, drilling from both sides of the river towards the center where the wellbores would meet.   The existing pipeline is 6 inches and 8 inches in diameter. The new pipeline would be 12 and 24 inches in diameter, a substantial increase in size that will allow an increase in volume of gas delivered.  The current pipeline can deliver 38 million standard cubic feet per day of natural gas; this would increase to 57.7 million standard cubic feet per day.  It is unclear how the added volume of gas would be used. The application states in several places that it will be for “future economic development”.  There is no discussion of the future development impacts, wrongly separating the rest of the project that would serve “future economic development” from the project being permitted at this time.  See DRN FERC comment below for more details.

Approximately 425 feet of the existing pipeline would be removed from the river bottom, 4,179 feet of existing pipeline on land near the Philadelphia Airport would be removed, and approximately 8,153 feet of the existing pipeline will be abandoned in place.  2.6 miles of new 12- and 24- inch pipeline would be installe , about 8,550 feet of it will be constructed using HDD. A new PIG launcher would be installed next to the Spectra metering site where the new pipeline would be connected, modifications would be made to the connection at the Paulsboro Refinery and a new tie-in facility that would include a PIG receiver, would be installed at the Paulsboro Refinery.  A “Y” would be installed at the end of the pipeline at the Paulsboro refinery, capped off.  The portion to be removed was damaged by the Deepening of the Delaware River navigation channel but that portion is not in the Federal Navigation Channel, it is in an area to the west of the channel.  The pipeline now in the river’s Federal Navigation Channel will be closed off and left abandoned in the bottom of the river.

On December 1, 2015, PNGPC submitted an Abbreviated Application for a Certificate of Public Convenience and Necessity, Blanket Authority and Request for Waivers (“Application”) with the Federal Energy Regulatory Commission (FERC).  An Environmental Assessment for the proposed project was published by FERC in January 2016 (Docket No. CP16-27-000).  DRN commented on the Environmental Assessment Notice of Intent.  DRN concluded that the project would have substantial adverse environmental impacts; that it threatens to significantly disturb the ecosystems, habitats, and water quality of the Delaware River, including its Estuary and Bay; and that it poses several unjustifiable public safety threats.  See comment below.

On September 7, 2016, FERC granted PNGPC the authorization it requested, subject to certain conditions.  On November 11, 2016, PNGPC filed its Implementation Plan, as required by Environmental

Condition No. 6 of the Order.  Some permits have been issued such as the stormwater permit from Delaware County Conservation District and certain township permits.

DRN Comment on the Coastal Zone Management Act (CZMA) to PADEP

On September 5, DRN submitted comment on the Coastal Zone Management Act (CZMA) to PADEP.  The project is inconsistent with the CZMA and CRMP.  It would trench through at least five acres of wetlands in an area where wetlands are scarce.  This direct effect on emergent and forested/shrub wetlands violates the CRMP’s policy to preserve, protect, enhance, and restore the remaining wetlands within the Commonwealth’s coastal areas.  The conversion of forested/shrub wetlands has lasting and devastating impacts yet these impacts are not addressed whatsoever, despite the CRMP requirement to mitigate for any lost wetland values.  The project would trench through the floodplain in the Delaware River coastal zone, actions that are inconsistent with the CZMA and Pennsylvania’s Coastal Resources Management Program (CRMP).  Trenching creates a high likelihood of erosion, particularly when used in flood-prone areas. Trenching for pipeline construction and removal of a portion of the old pipeline will result in sediment loading, an increase in turbidity, and an increase in total suspended solids.  

While removal will entail negative impacts, the old pipeline is planned, except for 425 feet, to be abandoned in the river bottom.  If left in the river to corrode, it will create a continuous source of heavy metal pollution, can release any remaining pollutants from the line, and will diminishing habitat for aquatic species.  All of these negative water quality and habitat impacts will directly affect aquatic species such as shad, herring, striped bass, and federally endangered Atlantic and shortnose sturgeon that rely upon them.  Any pipeline leak could have dire consequences for aquatic species.  Leaving the old pipeline in place will also cause future safety and hazard conditions for marine traffic and increase the likelihood of rupture and displacement of the line. DRN is opposed to any portion of the old pipeline being left in the river.The project contributes to the deterioration of the urban coastal environment in this area, in violation of CZMA policy.  Any flood event could expose the pipeline and result in damage and a catastrophic rupture.

Also, trenching produces a large amount of spoils but there is no discussion or proposals about how these spoils would be handled and disposed as is required under the CRMP.  Further, approval of this project would be in violation of the CRMP’s policy to reduce the risk of flood loss and could have negative thermal impacts that have not been examined.  The project will affect coastal uses or resources and DRN concluded that the CZMA approval should be denied. See comment below.

DRN Comment to PADEP on the Proposed Water Obstruction and Encroachment Permit 

On December 9, DRN submitted comment to PADEP on the proposed Water Obstruction and Encroachment permit and in opposition to the finding that the project meets the requirements of the Federal 401 Water Quality Certificate.  The Project does not comply with Chapter 105 of the Pennsylvania Code and is not consistent with 401 Water Quality Certification requirements in the Clean Water Act due to adverse impacts to waters and wetlands, adverse and unmitigated impacts on protected uses and on the maintenance and propagation of indigenous fish and habitat.  As mentioned above, potential impacts to the federally endangered species Atlantic sturgeon and shortnose sturgeon are not addressed by the Project.  In addition to the aquatic species already mentioned, important species of relevance for commercial fisheries include, among others, American eel (Anguila rostrata), bay anchovy (Anchoa mitchilli) and Atlantic menhaden (Brevoortia tyrannus) but these are also not considered despite the potential for negative impacts from the Project.

In addition to the impacts discussed above, the Project would disturb a minimum of 0.15 acres of Exceptional Value “Open Water”/Wetlands that is home to the state listed threatened/endangered species Pseudemys rubriventris (northern red bellied turtle) by drilling and by conducting construction activities above and around the pond and the habitat for the turtle. It would also permanently damage additional wetlands that should be classified as Exceptional Value to protect the habitat of the turtle but because of the mis-designation of the so-called ”Open Water” the protections that would apply for the turtle’s use of the wetlands are not applied by PADEP (there is no such designation in PA Chapter 93 water quality regulations as ”Open Water”, a fictitious term apparently invented for the Project).   The Project can reasonably be expected to have permanent impact on the turtles and their habitat, not a temporary impact as is claimed by the applicant.  Adequate protection for the turtles requires that there be no activity within at least 225 meters from the pond to provide available nesting area and that the time restriction be revised to include the nesting period (May-June), which is outside of the hibernation period of October to April.  There should be no drilling under the wetlands.  The nearby wetlands may be an important part of the habitat for these turtles, requiring that those wetlands also be classified as Exceptional Value and added to the protected area.  Additional protections are needed to preserve access to the river and feeding areas required by the turtles.  There should be a comprehensive analysis done of the site to assess the areas needed to be excluded and the time restrictions for any and all activity within at least a 225 meter radius of the pond.  Delaware Riverkeeper Network advocates that the work areas and Directional Drill Pullback Areas be moved from the proposed location to another location without Open Water or wetlands.

The project would also permanently degrade 6,436 square feet of streams and permanently impact at least 50 feet of floodway in the floodplain of the Delaware River.  It is claimed that the lay down area cannot be lengthened to remove the drilling further from the river because the length of the HDD drilling and pipeline construction is “at the limit of current technology”, bringing forward the question of the safety and technical soundness of drilling and maintaining such a long and deep well bore under a major waterway and Federal Navigation Channel.  The Pennsylvania construction site is simply too small for the activities planned.  It is also too small to provide adequate buffering between the Project and the river.  It can be expected that runoff from day to day operations could enter the river due to the proximity of the river and any spills, eruptions, accidental releases from the drilling operations could quickly effect the river and its water quality.  Options that do not require a river crossing must be considered but were not part of the environmental review process.

Additionally, Little Tinicum Island is located off shore and contains a heron rookery and could be home or foraging area for other species as well.  Species on nearby islands will be disturbed by the drilling noise, vibrations, lights, equipment emissions and round-the-clock construction activity related to the Project.  These potential harmful impacts are not addressed, discussed, or mitigated in any way. See comment below.

The PA state permits and the FERC approvals for the Project have been rushed through, seemingly to meet the construction schedule favored by the applicant. The opportunity for public comment and participation has not been very limited.  For all state permits, the public comment period should be extended because the applicant has submitted an incomplete application and inaccurate assessments and erroneous designations have been made, denying the public of the ability to effectively comment on the complete and accurate applications.