Both permits are associated with CNX Resource Corporation's Slickville Pipeline Project, which proposes to build a natural gas pipeline and a shale gas wastewater pipeline along a 13.9 mile route.
The appeals were filed as serious concerns surrounding potential environmental contamination and community health impacts were not addressed within the permits.
The CNX Slickville Pipeline Project expands across Bell, Loyalhanna, and Salem Townships in Westmoreland County, and aims to transport natural gas and wastewater from drilling operations.
Protect PT and Three Rivers Waterkeeper have provided substantial evidence of deficiencies regarding the permits during their open comment period.
The joint comments raised numerous issues related to the permit applications that were not addressed in the final approved permit.
Key problems include:
-- Permitting Inconsistencies: The PA Bulletin does not reflect that the Erosion and Sedimentation Control Plan (ESCP) application was revised and resubmitted in March 2024. CNX did not comply with Act 14 notification requirements to local governments, failing to provide updated notices to affected townships.
-- Environmental Concerns: The Chapter 102 Erosion and Sediment permit states that 30.9 acres will be disturbed, contradicting the Project Limit of Disturbance (LOD) of 228 acres. The application also does not sufficiently address the existing impairment of the Beaver Run Watershed, nor does it identify impacts to high-quality and exceptional value waters requiring specific protective measures.
-- Inadequate Analysis: There is no site-specific analysis of past land uses or the impacts to drinking water supplies. Additionally, the project’s assertions of remediation and restoration contradict environmental reports, suggesting a lack of comprehensive evaluation of potential pollution sources, including acid mine drainage.
-- Disregarded Recommendations: The Site Restoration Report recommends field adjustments to the land slope, sturdier pipeline construction, and anti-landslide measures in order to prevent catastrophic shifts in the ground around the pipeline that could result in landslides and subsidence. However, the project implements none of these critical safety measures.
“We had hoped in light of the 2020 43rd Grand Jury Report on fracking, scrutinizing PA DEP for its past failures, that the reviews of permits like these without addressing community concerns was a trend that would stop. It seems that the Shapiro administration’s DEP is just as much beholden to the fracking industry as previous administrations,” said Gillian Graber, Executive Director of Protect PT.
The project is also under scrutiny for its contributions to climate change. The Pennsylvania Climate Change Act of 2008 acknowledges that fossil fuel production significantly contributes to climate deterioration.
The issuance of permits for this project would affirmatively promote fossil fuel extraction, leading to increased greenhouse gas emissions, according to the groups.
The groups said DEP must review how the issuance of any permits for the project would exacerbate climate change by increasing downstream GHG emissions, but this information is not provided.
[Note: There is no present requirement for DEP to make this assessment.]
“At a minimum, the project will directly impact 54 wetlands, 43 streams, and 2 ponds, all of which contribute to the region's source of drinking water. The proposed pipeline would carry produced, highly radioactive water latent with heavy metals and PFAS chemicals, and any discharge or spill will have serious consequences to the environment and human health,” said Heather Hulton VanTassel, Executive Director of Three Rivers Waterkeeper.
The permit applications fail to identify the hazardous contaminants being carried by the produced water in the pipeline, and the project is devoid of any radiation monitoring, radiation protection plans, appropriate training, or emergency response procedures for highly radioactive substances.
Moreover, ongoing violations by CNX and CNX Midstream further undermine confidence in the project and are strong evidence that all deficiencies of the permits must be addressed to secure the protection of our environment and public health, the groups said.
The publicly available violation history of CNX Midstream indicates 290 violations, many recurring and outstanding through May 2024 with 53 open violations, many unresolved for years, and a history of non-compliance.
CNX Gas has approximately 1,365 entries for notices of violation, consent orders, and civil penalties in the last 10 years.
“CNX and CNXM should not be allowed to expand production when there are so many unresolved environmental violations and noncompliance” said Hulton VanTassel.
“This is a company that claims to be ‘radically transparent’ yet continues to violate our right to clean air and water,” said Graber.
Click Here for a copy of the appeal of Permit ESP076523001.
Click Here for a copy of the appeal of Permit E6507244-003.
Resource Link:
[Posted: November 4, 2024] PA Environment Digest
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