In a letter Tuesday responding to FERC’s May 10 order that suspended new horizontal directional drilling (HDD) for the Rover Pipeline, backer Energy Transfer Partners LP asked Commission staff to allow completion of two HDDs critical to laterals in Ohio and West Virginia.
The sites in question are HDD locations at Captina Creek in Belmont County, OH -- needed to complete the Clarington Lateral -- and at Middle Island Creek in Tyler County, WV -- necessary in order to finish the Sherwood Lateral. Last week the Federal Energy Regulatory Commission, responding to a 2 million gallon drilling fluid spill near the Tuscarawas River in Stark County, OH, ordered Energy Transfer to halt all new HDD work for Rover, including at the Captina Creek and Middle Island Creek locations.
But Energy Transfer told FERC Tuesday it has already started work at the Captina and Middle Island HDD locations.
Of the Captina Creek site, Energy Transfer told FERC it has transported drilling equipment and materials to the site, including grading work and "the installation of erosion control devices" to protect the creek.
"Any remedial action to withdraw and then re-disturb the area at a later date will greatly increase the likelihood of a release from surface erosion into the creek, which is directly contrary to the intended purpose of the HDD, the careful planning that has occurred, and the expectation of avoidance of impacts," Energy Transfer wrote. "Accordingly, Rover believes that executing this HDD now, in as expeditious a manner as prudent responsible drilling practices will allow, is the most responsible course of action."
The company also noted that the Captina Creek HDD would accommodate the 42-inch Clarington Lateral, which is part of the first phase of the project planned to go into service by July. "By allowing Rover to complete the Captina Creek HDD, installation of pipe for the Clarington Lateral could be completed and the area restored immediately," the company wrote.
Energy Transfer said it has completed about 60% of the pilot phase of drilling at Middle Island Creek. It said stopping HDD work "at this juncture adds additional complexity and unnecessary risk" to "the waterbody, which the HDD was intended to protect."
Stopping work "could effectively result in additional costs to Rover, which are not justified as Rover is in compliance with its FERC certificate as well as its state and Federal permits...Similar to the Captina Creek HDD, the Middle Island Creek HDD...also involves only a single pipeline, and this area could be restored immediately after the drill at this location is complete, decreasing potential impacts to the environment."
Prior to FERC's HDD order, the Ohio Environmental Protection Agency (Ohio EPA) issued a series of proposed administrative orders that included $431,000 in proposed civil penalties for what the agency characterized as violations of state environmental laws, including the Tuscarawas HDD spill. Ohio EPA also reached out to FERC for help, saying Energy Transfer had challenged the state agency's enforcement authority.
Energy Transfer said it shares FERC staff's "general concerns" regarding the spill at Tuscarawas River. The operator said it immediately implemented its HDD contingency plan to address the spill and is "committed to full restoration of the wetland."
The company said it has also taken the step of retaining the services of GeoEngineers, "an expert HDD engineering firm specializing in geotechnical and environmental issues." The firm is providing analysis to help prevent future inadvertent releases, Energy Transfer said.
"But given the gravity of the situation, we will not stop there. Rover has also mobilized additional construction/environmental personnel at each HDD site to increase pedestrian surveillance for potential inadvertent returns to ensure that any inadvertent release is observed at the earliest possible time," the company told FERC. "Rover has also expanded the pedestrian inspection radius to monitor for inadvertent releases on surrounding properties, and is now deploying aerial drones to help monitor for inadvertent releases at each HDD site."
Energy Transfer said it has also prepared the request for proposals for a third-party contractor to review the Tuscarawas incident, per FERC's instructions.
Last week's action from FERC caused a stir among natural gas futures traders, with the 3.25 Bcf/d mega-project poised to reshape markets as it opens up new takeaway capacity from the Marcellus and Utica shales.
The 711-mile Rover project would transport gas from producing areas of Pennsylvania, Ohio and West Virginia to markets in the Midwest, Gulf Coast and Canada. After a long regulatory review process, Rover is on a tight schedule, and FERC's halt on new HDD work led to market speculation of a potential delay to the project timeline.
Rover's Phase 1 -- extending to the Midwest Hub in Defiance, OH -- is scheduled to come online in July, with Phase 2 -- connecting to the Vector Pipeline in Michigan and to the Dawn Hub in Ontario, Canada -- scheduled for service in November.