Sunoco Logistics L.P.’s Request to Become a Public Utility Corporation – Just Say No!

Sunoco Pipeline L.P. (“SPLP”) proposed ethane/propane pipeline (“Project Mariner East”) from Houston, PA to the Sunoco Partners Marketing & Terminals L.P. terminal in Marcus Hook, PA and Claymont, DE (the “SPMT Terminal”). Shippers have expressed interest in an expansion of Project Mariner East to provide capacity for transportation of ethane, propane and butane.

To: PA Public Utility Commission

From: League of Women Voters of PA

Date: April 21, 2014

Comments to PUC on Docket number P2014-2411966
Sunoco Logistic L.P.’s Request to Become a Public Utility Corporation

The League of Women Voters of PA strongly urges PUC to deny Sunoco Logistics L.P.’s petition to be granted status as a public utility corporation in 31 townships along the proposed Mariner East Pipeline. The League opposes any attempts to exempt corporations from local zoning since we believe those rights belong to local officials who represent the citizens of those communities. Sunoco is a common carrier under FERC and therefore not deemed a public utility and so the company is not entitled to this status. Also, the proposed pipeline and pump and valve stations are not reasonably necessary for the convenience or welfare of the public, therefore not entitling the company to an exemption. In addition, granting the petition would violate Article 1 Section 27 of the PA Constitution as per the December 19 ruling of the PA Supreme Court.

In addition to these reasons for denial of the petition, the League would like to add the following reasons why permitting this request would not be in the interest of the people of our Commonwealth:

1. It would be unsafe to “repurpose”decades old pipelines that were constructed to carry conventionally drilled petroleum oil from abroad to western PA for the new purpose of transporting highly volatile and much more explosive wet gas that Sunoco wants to bring from southwestern PA to Marcus Hook for processing and shipment to other markets (which already have multiple choices of gas supplying companies). Because any natural gas or oil extracted from Marcellus Shale is likely to be radioactive, this adds another potential danger.
2. The pressure under which this highly flammable liquid gas would be transported (according to the Sunoco Logistics L.P. website) would be much greater than was the case with the previous westward shipments of conventionally produced oil), adding to the possibilities of leaks and explosions – at pumping stations, at valves and along the entire pipeline.
3. Unlike methane which tends to rise and dissipate into the atmosphere (though it also has explosion hazards), liquid natural gas is far more dangerous if leaks or explosions occur. Safety expert Richard Kuprewics has stated, “The liquid propanes and ethanes, they’ll tend to hug the ground and they don’t have to necessarily be trapped in a building. They can detonate on their own.” These liquid gases are colorless, tasteless and odorless.
4. Please consider the following direct excerpts from information published on Sunoco Logistics L.P.’s website:

Health Hazards

Easily ignited and will form explosive mixtures with air

May cause dizziness

May be toxic if inhaled in high concentrations

Skin contact with gas or liquefied gas may cause burns, severe injury and/or frostbite

Fire may produce irritating and/or toxic gases

911 personnel play a critical role in effective response to pipeline incidents

Will form explosive mixtures with air

Containers may explode when heated

Cylinders may explode when heated

Ruptured cylinders may rocket

In addition, emergency responders are warned to wear SCUBA gear for breathing, told that protective clothing may still be inadequate for skin protection, to stay downwind, to try and evacuate people within a mile in all directions if a leak or explosion occurs and to stay out of low or confined areas (sewers, basements and tanks are places to avoid).

The Public Utility Commission was appointed to supervise our public utilities without adding these types of dangers to the people who live or work near the proposed Mariner II pipeline and the infrastructure that would be needed for the Sunoco Logistics Project. Please vote NO on this project!