Middletown Township Delaware County
12 September 2016 Council Meeting
Statement Regarding Proposed Mariner East 2 Pipeline
To the attention of Mark Kirchgasser, Norman Shropshire, Scott Galloway, Dean Helm, Jr., Russ Carlson,
Christopher Quinn, and Susan Powell and any other members of Middletown township town council

My name is Seth Kovnat. I live at 75 War Trophy Lane with my wife and 2 small children, both of whom
will be attending Glenwood Elementary. I have a master’s degree in Mechanical Engineering and am the
Chief Structural Engineer for Piasecki Aircraft Corporation, a local Delaware County company that
specializes in developing new technologies for the aerospace industry. My background in piping is
extensive. I led the tubing analysis effort for NASA’s Orion program and have designed, analyzed, and
overseen tubing efforts for R&D aircraft.
When I first learned of the proposed Mariner East 2 pipeline project that could run through the heart of
Middletown Township, I was more than a little concerned considering the sheer size, pressures, and
materials involved that rival or exceed anything I've seen in my experience with rocket thrusters. I had an
expectation that a pipeline within public range would have more regulations, oversight, and requirements
than airplanes or spacecraft. Failure is simply not an acceptable option when the lives and property of so
many people are involved. I am appalled to learn that this is simply not the case. Now, some of the
procedures in place are very similar to what I am used to seeing with regard to certified welders,
destructive/ non-destructive testing, inspection, and proof testing. However, other factors, such as
corrosion, trench digging effects, and emergency protocol are simply not addressed in a serious way.
Even if everything is installed perfectly, the risk is still significant, especially since this pipeline will be here
“forever”, long enough for most citizens to forget about the associated risks. There are always unknown
events that can cause pipe failure and on pipes this large and pressurized to these levels, failure is simply
catastrophic. Given enough time (and forever is enough), something will happen. Nothing is foolproof,
and Sunoco’s abysmal safety record indicates that a leak or breach might occur sooner rather than later.
And the potential consequences of that breach are enormous.
Let me give a little perspective from an engineering standpoint of what a breach would look like on a 20
inch diameter, 1,500 PSI pipeline containing highly volatile liquids. First, the leak would need to be
detected by Sunoco, a company whose operating safety systems have failed to detect at least 25% of the
leaks on its pipelines over the last ten years. Next, the valves on either side of the leak would need to be
closed. These valves will be at least 6 miles apart. It can take 10-30 minutes from the time a leak is
identified to the time the shutoff valves are fully closed.
But let’s suspend disbelief and imagine for a moment a best case scenario where the leak is identified
and the valves are shut off immediately. Even in this case, the entirety of the volatile liquid within that 6
mile pipeline segment, over 500 thousand liquid gallons, will become depressurized, convert from liquid to
gas, and escape into the air. When these materials become gaseous, they increase in volume by about
500 times, meaning over 300 million gallons of heavier-than-air, explosive gas would blanket the
surrounding area, potentially asphyxiating anyone in its path even before finding an ignition source.
Assuming the gas spreads over 300 acres of flat topography, the 300 million gallons of heavier-than-airgas would fill up from the ground to a height of about 3 and a half feet, about the size of the children that
congregate at nearby Glenwood Elementary School and Sleighton Park. It would completely engulf any
lower lying areas in gaseous fuel. One spark to the over 2.5 million pounds of propane, ethane, or butane

 Middletown Township Delaware County
12 September 2016 Council Meeting
Statement Regarding Proposed Mariner East 2 Pipeline
gas and the entire gas cloud will ignite, creating a 3,600 degree F fire blanket with energy equivalent to
over 15 kilotons of TNT and equal to the energy in “Little Boy”, the nuclear bomb dropped over Hiroshima.
An ignition source could come from anywhere - a car engine, a doorbell, a garage door opener, a cell
phone. A leak or explosion in a pipe this large would impact a radius of at least half a mile, over 300
acres. Explosions and leaks of this magnitude have occurred in NGL pipelines before. In fact, a leak
occurred on a Sunoco pipeline just down the road in Aston this year. None of the escaped gas was
recovered. Luckily there was no spark. But counting on luck is not a credible plan.
Sunoco’s generic emergency protocol suggests that in the event of a known or suspected leak, residents
should quickly move away from the pipeline on foot, upwind, to a distance of at least half a mile. As I
stand before a group of reasonable people, I must ask you, is this reasonable plan? For residents to be
able to determine the direction of the wind, and then run through potentially rough terrain, over fences,
around buildings, through woods? Now imagine running carrying a small child, or your elderly parent, in
the cold, or through a snowstorm, with your lungs filling up with ethane or butane or propane. What if the
pipeline is upwind? What if the wind changes direction? How do we evacuate schools or preschools or
elder care facilities under this plan? Is evacuation even possible? There is no odorant added to these
materials to allow people to even smell the odorless gas, so maybe we don’t even know a leak has
occurred until it is too late for anyone to run.
Sunoco has simultaneously managed to downplay these risks and create a scenario where the public
feels we have no choice but to accept these risks. To those who believe this is just another pipeline, I am
here to tell you that it is not typical, not a utility, and carries many thousand times the risk of other pipes in
the ground, perhaps the lone exception being Mariner East 1.
The difference:
1) Propane, ethane, and butane are 10 times more volatile than petroleum products, and they are
gaseous, as opposed to liquid, when in the environment, much more difficult to contain when leaks occur.
2) The extreme internal pressures being used put the pipeline under incredible stress, increasing the
likelihood of rupture, and making any incident one of epic proportions. The utility gas lines distributing to
homes are at pressures 2 orders of magnitude lower and are gas inside the pipe.
3) The large pipe diameter allows an insane amount of liquid NGL to be packed into each pipe segment,
ensuring that any leak will be catastrophic with plenty of fuel to feed an epic explosion. Utility gas lines
are typically 2in diameter with 100 times less flow area and 50,000 times less fuel mass since utility gas is
transported as a gas.
4) Finally, the proximity to densely populated areas, containing homes, schools, hospitals and businesses
means that thousands of people are at risk every day.
As an engineer with knowledge of pipes, I know that installation is critical to the performance and
longevity of the pipeline. Inadequate installation, including trench digging, welding, inspection, and testing
can result in failure of the pipeline during operation. Embrittlement and corrosion can attack inadequately
welded joints and sections of pipe with compromised coatings. Compounding things further is that it is
unusual to find seamless tubing over 18 inches in diameter. This means that the proposed 20 inch pipe
will likely be made from rolled plate that gets seam welded at the steel mill. This seam-welded pipe is not
as reliable as continuous-wall or drawn pipe and further increases risk, as recent structural failures have
graphically illustrated.

 Middletown Township Delaware County
12 September 2016 Council Meeting
Statement Regarding Proposed Mariner East 2 Pipeline
Inadequate pipe welds may or may not cause the pipeline to fail proof testing. So it is possible for the pipe
to pass proof testing and still be inadequate and fail prematurely. Sunoco claims its procedures are
sound. However, there have been numerous times when Sunoco has received major federal enforcement
action for not following their own procedures and federal safety regulations. One enforcement action was
brought by the federal government against Sunoco in April 2016. The federal regulator found that Sunoco
used unqualified personnel to perform 3,000 welding operations on a new pipeline. Rather than rectify the
problem, Sunoco attempted to “back-qualify” the welders, some of whom were unable to perform
satisfactory welds even after multiple attempts. The federal government has proposed a $1.278 million
dollar fine against Sunoco as a result of its investigation.
Consistent maintenance over the lifetime of the pipeline is absolutely critical since we are talking about a
forever timeline. Corrosion is a real concern as it is a contributor to many pipeline failures that have
occurred. Steel corrodes. New high tech coatings provide significant improvements (believe me, I use
them every day), but eventually, they will wear away. Smart PIGs and other inspection techniques are
able to clean and inspect the inside of the pipe. However, there really is no reliable way to inspect the
outside of an underground pipe for cracks and corrosion. Burrowing these pipes into deep trenches or
holes, with the pipes scraping along the edges of hollowed out soil will set the pipe on a course for
expedited corrosion.
Again, this is not a hypothetical concern. Sunoco is the owner of the industry-high number of reported
incidents, with 26 having occurred in Pennsylvania. The vast majority of these hazardous liquids leaks
were caused by one of three causes: corrosion, incorrect operation, or material/weld/equipment failure.
As an example not far from here, a Sunoco petroleum pipeline failed due to corrosion in Edgmont
Township. The leak was detected by the property owner, not by Sunoco’s operating detection system.
Shortly after the leak, Sunoco was delivering bottled water to surrounding residences; a few days later,
Sunoco found MTBE, a gasoline additive, in a nearby well water. The causes of this event appear to be
corrosion; Sunoco’s failure to detect the corrosion; and Sunoco’s failure to detect the leak.
Sunoco claims to have been operating HVL pipelines safely and for a long time. However, they cannot
claim that they have never leaked these materials. Consider the following examples:
1) Oregon OH, September 2014
2) Beaumont TX, January 2015
3) Again in Oregon OH, June 2015
4) Again in Beaumont TX
5) Finally, down the road in Aston PA, May 2016
I would say that accidentally leaking volatile NGL gas into neighborhoods is not demonstrating safe
operation. These leaks did not yield an explosive conclusion. However, there are plenty of examples
throughout the US and the world where NGL leaks of similar magnitude have led to devastating
explosions. Maybe Sunoco has a different definition of the word "safe."
Protecting the installed pipeline from future digging or tampering is imperative to preventing failure in the
line. In highly dense areas, the pipeline will be at risk of people digging on their private properties.
Although the township provides underground utility marking prior to any excavation project, people
sometimes circumvent that process if they themselves deem that it is not important. At any time people
living on these lands may not be aware of the pipeline’s presence, and could accidentally dig into the

 Middletown Township Delaware County
12 September 2016 Council Meeting
Statement Regarding Proposed Mariner East 2 Pipeline
pipeline, causing explosive failure. Sunoco also notes the risk of the pipeline being used as a terrorist
target in their own literature for first responders. I absolutely agree.
In summary, the Mariner East 2 pipeline is a wildly unnecessary public health and safety risk to the
residents, businesses, and visitors of Middletown Township. It is a classical industrial pipeline of epic
proportions unlike anything currently operating in a densely populated area. Its sole purpose: serving to
improve the bottom line of Texas-based Sunoco as this material is shipped overseas. The pipeline is not
a sustainable source of jobs. It may introduce a few new local jobs for a minute. Given Sunoco’s
connections to the Gulf and the downturn in the oil industry down there, even that is not a guarantee.
Actually, the likeliest long term jobs to result from this proposed project are environmental remediation
specialists and pediatric asthma physicians. Regardless, as soon as installation is complete, most jobs
will vanish. Our community will be left only with the anxiety of knowing that a ticking time bomb is literally
running under our feet, jeopardizing our safety, our quality of life, and our property values, all at the same
time. Sunoco has demonstrated time and time again that they are incapable of keeping their materials
contained within their pipes, and we simply cannot entrust them with ours and our children’s lives, not for
any price.
Sincerely,
Seth Kovnat
75 War Trophy Lane
Middletown Coalition for Community Safety