Shell Pipeline Spill Complaint

COMMONWEALTH OF PENNSYLVANIA POLICE CRIMINAL COMPLAINT (
COUNTY OF:WASHINGTON ‘COMMONWEALTH OF PENNSYLVANIA

‘Magisterial District Number. 27-3-06 Vs.
(NAME and ADDRESS):
MDJ: Hon. Louis J. McQuillan
Riess Sute Niles Run Road,
3441 #105
DEFENDANT:
SEL
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Cecil, PA 15321 150 NorthDairyAshford
Houston, TX 70779
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Telephone: (724)746-8515
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2 POLICE CRIMINAL COMPLAINT
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DefendantName: SHELL. PIPELINE COMPANY LP
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‘Statute Description (include the nameofstatute or OrdiNGNCE): CLEAN STREAMS LAW, UNLAWFUL CONDUCT,35P.S. §691.611,A
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CLEAN STREAMS LAW, UNLAWFULCONDUCT, 35 PS. § 691.611,A
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‘Acts of the accused associated with this Offense: Sec Continuation Page. -
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SHELL PIPELINE COMPANY LP
The acts commited by the accused are described below with each Actof Assembly or statute aileged vies:
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SHELL PIPELINE COMPANY LP
9 acts commited bv the accused are described below with each AcofAssembly or statue allegedly violated, if
appropriate. Vien there i more than one offense, each offense shouid be numbered chronalogicall.
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APC 412A
~ Rev. 07/10 page
b of 4b
E- POLICE CRIMINAL COMPLAINT
_OFFENSE CONTINUATION PAGE
Er] effi | OTWLveSGan Number | Complaint Number | Incident Number
(RR Fat
[iE ide Te
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OFFENSE DESCRIPTION CONTINUATION
Offense # 1: The Defendant, Shell Pipeline Company LP, by its own conduct or conductofanother, pursuant to
18 Pa CS.A. §307, did fail to comply with any rule or regulationofthe department or fail to comply with any
order or permit of license of the department, violated anyofthe provisions of this act or rules and regulations
‘adopted hereunder, or any order or permit or licenseofthe department, caused air or water pollution, or
hindered, obstructed, prevented, or interfered with the department or its personnel in the performance of any
duty hereunderorviolated the provisions of 18 Pa C.S. § 4903 or §4904. To wit: On April 22, 2019, during the.
construction of the Shell Falcon Pipeline, the Defendant, Shell Pipeline Company LP, did negligently hinder the
department by failing to report a 21,000 gallon LOC at the Houston #7 HDD, as required under Title 25 Pa Code
§782.68().
Offense #2: The Defendant, Shell Pipeline Company LP, by its own conduct or conductofanother, pursuant to
18 Pa C.S.A. §307, did fail to comply with any rule or regulationofthe department or fal to comply with any
order or permit or license of the department, violated anyofthe provisions of this act of rules and regulations
‘adopted hereunder, or any order or perto license of the department, caused ai or water pollution, or
hindered, obstructed, prevented, or interfered with the department or its personnel in the performanceof any
duty hereunder or violated the provisions of 18 Pa C.S. § 4903 or §4904. To wit: On April 24, 2019, April 25,
2019, and May 9, 2019, during the construction of the Shell Falcon Pipeline, the Defendant, Shell Pipeline
Company LP, did negligently hinder the department by failing to report multiple IR at the Houston #2 HDD, as
required under Title 25 Pa Code §782.682(7).
Offense #3: The Defendant, Shell Pipeine Company LP, by its own conduct or conductofanother, pursuant to
18 Pa C.5.A. §307, did fail to comply with any rule or regulationofthe department or fai to comply with any
order or permit or licenseofthe department, violated anyofthe provisions of this act or rules and regulations
adopted hereunder, or any order or permit or license of the department, caused air or water pollution, or
hindered, obstructed, prevented, or interfered with the department or its personnel in the performanceofany
duty hereunder or violated the provisions of 16 Pa C.S. § 4903 or §4904. To wit: On July 7, 2019, during the
construction of the Shel Falcon Pipeline, the Defendant, Shell Pipeline Company LP, did negligently hinder the
department by failing to report a 50 gallon IR at the Houston #10 HOD, as required under Title 25 Pa Code
§782.68a().
AOC 412A - Rev. 12/21 Page of 4

#4 POLICE CRIMINAL COMPLAINT
OFFENSE CONTINUATION PAGE
CPR
Se [Jd
Fist ide Tit Soir
9.001258
ovnsmitene [Sie Epon2
Offense # 1; The Defendant, Shell Pipeline Company LP, by its own conduct or conductofanther, pursuant to
18 Pa C.5.A. §307, id fal to comply with any rule or regulation of the department or fail to comply with any
order or permit or license of the department, violated anyof the provisions of this act or rules and regulations
adopted hereunder, o any order or permit or license of the department, caused ai or water pollution, or
hindered, obstructed, prevented, o interfered with the department o ts personnel in the performanceofany
duty hereunder or violated the provisions of 18 Pa C.S. § 4903 or §4904. To wit; On Apr 22, 2019, during the
constructionof the Shell Falcon Pipeline, the Defendant, Shell Pipeline Company LP, did negligently hinder the
department by failing to reporta 21,000 gallon LOCatthe Houston #7 HDD, 2s required under Title 25 Pa Code.
§782.682(1).
Offense #2: The Defendant, Shell Pipeline Company LP, by its own conduct or conduct of another, pursuant to
18 Pa CS.A. §307, did fal to comply with any rule or regulation of the department or fal to comply with any
order or permit or license of the department, violated anyof the provisions of this acto rules and regulations
adopted hereunder, or any order or permit or licenseofthe department, caused air or water pollution, or
hindered, obstructed, prevented,o interfered with the department or ts personnel n the performance of any
duty hereunder or violated the provisions of 18 Pa C.S. § 4903 or §4904. To wit: On April 24 2019, Apri 25,
2019, and May 9, 2019, during the constructionofthe Shel Falcon Pipeline, the Defendant, Shel Pipeline:
Company LP, id negligently hinder the department by fang to report multiple IRs at the Houston #2 HDD, as
required under Title 25 Pa Code §752.68a(1).
Offense #3: The Defendant, Shell Ppeline Company LP, by ts own conduct or conductof another, pursuant to
18 Pa C:5.A. §307, did fall to comply with any rule or regulationofthe department or ail to comply with any
order or permit or license of the department, violated any of the provisionsofthis act or ules and regulations
hindered, obstructed, prevented, of interfered vith the department or ts personnel in the performance of any
duty hereunder or violated the provisions of 18 Pa CS, § 4903 or §4904. To vit: On July 7, 2019, during the
construction of the Shell Falcon Pipeline, the Defendant, Shell Pipeline Company LP, did negigently hinder the
department by fang to report a 50 gallon IR at the Houston #10 HOD, 35 required under Tite 25 Pa Code
§780.68a().
AOPC 412A — Rev. 12/21 paged of 4,

DRA Caf Fld: | OTNILivaSean Number | Complaint Number | Incident Number
PRE bah
Fist, + © idde Tat
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Offense # 4: The Defendant, Shell Pipeline Company LP, by its own conduct orconductof another, pursuant to
18 Pa C.S.A. §307, did fail to comply with any rule or regulation of the department or fai to comply with any
order or permit or license of the department, violated any of the provisions of this act or rules and regulations
adopted hereunder, or any order or permit or licenseofthe department, caused air or water pollution, or
hindered, obstructed, prevented, or interfered vith the department or its personnel in the performance of any
duty hereunder or violated the provisions of 18 Pa C.S. § 4903 or §4904. To wit: From September 28, 2019 to
November 7, 2019, during the construction of the Shell Falcon Pipeline, the Defendant, Shell Pipeline Company
LP, did negligently hinder the department by failing to report multiple IRs at the Houston #1 HDD, as required
under Title 25 Pa Code §782.68a(i).
18 Pa C.5.A. §307, did fail to comply with any rule or regulationof the department or fai to comply with any
duty hereunder or violated the provisions of 18 Pa C.S. § 4903 or §4904. To wit: On February 3, 2020, during
the construction of the Shell Falcon Pipeline, the Defendant, Shell Pipeline Company LP, did negligently hinder
the department by failing to report a 19,116 gallon LOC at the Houston #8 HDD. On May 13, 2020, Shell
Pipeline Company LP failed to reporta 2,800 gallon IR at the Houston #8 HDD, as required under Title 25 Pa
Code §78a.68z().
18 Pa C.S.A. §307, did fail to comply with any rule or regulationof the department or fail to comply with any
hindered, obstructed, prevented, or interfered with the department or ts personnel in the performance of any
duty hereunder or violated the provisions of 18 Pa C.S. § 4903 or §4904. To wit: On February 25, 2020, during
the construction of the Shell Falcon Pipeline, the Defendant, Shell Pipeline Company LP, did negligently hinder
the department by failing to report a 200 gallon IR at the Houston #3 HDD. On August 4, 2020, Shel Pipeline:
Company LP did fal to report a 6,184 gallon LOC at the Houston #3 HDD, as required under Tite 25 Pa Code
§782.682().
AOPC412A- Rev. 12/21 paged of 4

_ OFFENSE CONTINUATION PAGE
(REE [Geom cident Number
(RES L at.10 St iia: Tar 49-0015 |
Setordantiame: SHELL PIPELINE COMPANY LP
Offense #7: The Defendant, Shel Pipeline Company LP, by its own conduct or conduct ofanother, pursuant to
18 Pa C.5.A. §307, did place, or permitted to be placed, or discharged or permitted to flow, or continued to
discharge or permit to flow, into any watersof the Commonwealth any industrial wastes. To Wit: During the
construction of the Shell Falcon Pipeline, the Defendant, Shel Pipeline Company LP, id negligently discharge
drilling fluid, an industrial waste, into waters of the Commonwealth on April 22, 2019 and May 29, 2019 at the
Houston #7 HDD. The Shell Pipeline Company LP experienced two (2) IRS at this location, resuiting in a release:
ofdrilling fuids to two (2) UNTS to Potato Garden Run, (S-PA-160405-JLK-001 and S-PA-161205-WRA-001) and
2 wetland (W-PA-160405-JLK-001).
Offense #8: The Defendant, Shell Pipeline Company LP, by its own conduct or conduct of another, pursuantto
18 Pa C.5.A. §307, did put or place into any waters of the Commonwealth, or allowed or permitted to be
discharged from property owned or occupied by such person or municipality into any watersofthe
Commonwealth, any substance of any kind or character resulting in pollution as herein defined. Any such
discharge is hereby dedared a nuisance. To wit: During the construction of the Shel Falcon Pipeline, the
Defendant, Shell Pipeline Company LP, did negigently allow or permit the discharge of driling fluid, a substance
resulting in pollution, into waters of the Commonwealth on April 22, 2019 and May 29, 2019 at the Houston #7
HDD. The Shell Pipeline Company LP experienced two (2) IRs at this location, resulting in a release of driling
fluids to two (2) UNTS to Potato Garden Run, (S-PA-160405-JLK-001 and S-PA-161205-WRA-001) and a wetland
(W-PA-160405-JLK-001).
Offense #9: The Defendant, Shell Pipeline Company LP, by its own conduct or conduct of another,pursuantto
18 Pa C.5.A. §307, did place, or permitted to be placed, or discharged or permitted to flow, or continued to
discharge or permit to flow, into any watersof the Commonwealth any industrial wastes. To Wit: During the
construction of the Shell Falcon Pipeline, the Defendant, Shel Pipeline Company LP, cid negigently discharge,
permit to flow, or continue to discharge or permit toflow driling fuid, an industrial waste, into watersofthe
Commonwealth on July 22, 2019 at the Houston #9 HDD. The Shell Pipeline Company LP experienced an IR at
this location, resulting in a releaseofdriling fluids to Raccoon Creek: (5-PA-15103-MRK-002) and a wetland (W-
PA-151013-MRK-003).
Offense #10: The Defendant, Shell Pipeline Company LP, by its own conduct or conductof another, pursuant to
18 Pa CS.A. §307, did put or place into any waters of the Commonwealth or zllowed or permitted to be
discharged from property owned or occupied by such person or municipality into any waters of the
Commonwealth, any substance of any knid or character resulting n pollution as herein defined. Any such
discharge is hereby decired a nuisance. To wit: During the constructionofthe Shell Falcon Pipeline, the
Defendant, Shell Pipeline Company LP, did negigently allow or permit the discharge of driling fluid,a substance
resulting in pollution, into watersofthe Commonwealth on July 22, 2019, at the Houston #9 HDD. The Shell
Pipeline Company LP experienced an IR at this location, resulting in a releaseofcriling fluids to Raccoon Creek,
(5-PA-15103-MRK-002) and a wetland (W-PA-151013-MRK-003).
AOPC 412A Rev. 12/21 Pegeld of 4b

oi POLICE CRIMINAL COMPLAINT
en Pats Fie, OTNILiveScan Number | Complaint Number | Incidnt Number
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Offense# 11: The Defendant, Shell Pipeline Company LP, by its own conduct or conduct of another, pursuant.
to 18 Pa C.S.A. §307, did place, or permitted to be placed, or discharged or permitted to flow, or continued to
discharge or permit o flow, into any watersofthe Commonwealth any industrial wastes. To Wit: During the
construction of the Shell Falcon Pipeline, the Defendant, Shell Pipeline Company LP, did negigently discharge,
permit to flow, or continue to discharge or permit to flow driling fluid, an industrial waste, into watersof the
Commonwealth on September 20, 2019,atthe Houston #11 HDD. The Shell Pipeline Company LP experienced
an IR at this location, resulting in'a release of drilling fuids to a wetland (W-PA-151123-JKL-001).
Offense #12: The Defendant, Shel Pipeline Company LP, by its own conduct or conduct of another, pursuant to
18 Pa C.S.A. §307, did put or place into any waters of the Commonwealth, or allowed or permitted to be
discharged from property owned or occupied by stich person or municipaiity into any waters of the
Commonwezlth, any substance of any knid or character resulting in pollution as herein defined. Any such
discharge is hereby deciared a nuisance. To wit: During the constructionofthe Shell Falcon Pipeline, the
Defendant, Shell Pipeline Company LP, did negigently allow or permit the discharge of driling fluid, a substance
resulting in pollution, into waters of the Commonwealth on September 20, 2019, at the Houston #11 HDD. The
Shell Pipeline Company LP experienced an IR at this location, resuiting in a release of drilling fluids to a wetiand
(W-PA-151123-JLK-001).
18 Pa C.5.A. §307, did all to comply with any rule or regulation of the department or fail to comply with any
order or permit or license of the department, violated any of the provisionsofthis act or rules and regulations
duty hereunder or violated the provisions of 18 Pa C.S. § 4903 or §4904. To wit: From April 2019 to on/about
November 2019, during the construction of the Shell Falcon Pipeline, the Defendant, Shel Pipeline Company LP,
did fail to comply with the DEP permit conditions which required real-time data logging capabilties on the HDD
drilling rigs operated by Ellingson Trenchless, as per the HOD IR Pian.
AOPC 412 Rev. 12/21 pagel] of 46

1. Your Affiant is employed as a Special Agent (SA), assigned to the Environmental Crimes Section
(ECS) as a criminal investigator by the Bureau of Criminal Investigations, Pennsyiaria Office of
Aor General (PA OAG), located at 2515 Green Tech Drive, Sate College, PA 16003. Your
Affant hasbeen so employed since 2016. Prior, Your Afant servedas2 Woricpal Pic Offer
fom 1955to 2018. In the corse of employment, Your Aan nas conducted hundreds of criminal
investigations. As a Special Agent, Your Affant authorizedtoconduct investigations into
Suspected cririnal vilaions ofthe Pennsylvania Crimes Code and the Pemsyiaria
Environmental Sates. The OAG ECS Agen work cooperatively wih aca aw enforcement
officals and Pennsyivania regulatory agencies such as he Depariment of Envionmenta
Protection (DEP) wich do ot have the resources orJurisdiction o vestigate potent!
environmental viatons wich re criminal ofenses.
2. On October 6%, 2018, tne Office of Atomey General (0A), Environmental Crimes Secon,
assumed juscicion ns mater, pursuant to te Commonwealth Atomey's Ach 71 P.5.§ 732-
206 (aE). This cane was referred othe OA a he request of Deputy Genera Counsel Amn
Gingricn Conic,of tre fice of General Counselin a formal request dated Ocaber 2, 2015.
3. The refertal fom the Departmentof Envionmenta Protection (DEP) alleges potas vations of
the Clean Sreams Law and he Dam Safely Encroachments Actby he Shel Pipeine Company.
LP (SPL), and Minnesota Lined, LLC (MLL) for cines occuring in Alegheny, Beaver, and
Wstington Counties, SPLC and MLL ae c-permitees of tre Falcon Etnene Pipeine System
inspector forte Falcon Pipeline accused
envionmentalofinadvertent
SPLG ndPipeline
(Falcon f feportAformer
Pipeline).
MLof orling anor aseeporig reums (IR)ofdling fuids
‘associated with horizontal directional drilling (HDD) activities.
4. Glossary of terms used in his Criminal Compl, a defied by “Trenciesspedia. con

Horzontal drestional dng (HDD) a rencess construction method used to ns pes
underground wihout disurbing the ground suace. Th ils launched from ane en of he
designed bore path and reioved at (ne cine end, and excep for th launch and retfivig spaces
“bo ground, ihe ei process fakes place Underground, out of sight. HOD has become a choice
aerate oconventional ppedaying melhods (a require opening up the ears surface up one
depth of staan o he entre pipeline rote. Horizontal rconal rn sea for use where
{enching needs a be avoid uch a undera alo, an embankment, hay, and beneath
Iakes an fers, Wi avanced HOD steering technology, 5 50 now possi fonts pipelines
under busy ity svets wihout disrupting thefw of afc and affecting Businesses.
Dring fui o arling mud s mixofwater and her components, such asBente ht hes 2
sore matin Ho shape Toughout ihe borg processwhile loosening the mata youre dling
rough.
Loss. of Giclation (LOG) o Loss of elu (LOR) can be defined 2 th loss of cling mu
underground and lo th roc formation tig ling operations. Nu loss f noticed when here
15a ackof anling mud eturing {0 the surface no thepretermined ey of xt pis,
in naverient retu (1R) i he intended surfacing of crilng mud 0 the surface of th gourd,
outside
ofre entry or ex pit during boring mactine operons
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5. Overview
ofthe Shell Falcon Ethane Pipeline System: Shell Pipeline Company, LP (SPLC) built,
wns, and operate tho Shel Falcon Ethane Pipeline Sysem. The Falcon Fipeine consists of an
approximately 97.43 mile common carer ean supply hats located n scuhwestem
Panneyiani, Oho, and West Vigna. The ipeine connect thre () major ethane sources in
Houston, Pennsyhani, Scio, Oi, and Gad, Oni to Shell Chemicals Pemnsylania
Petrochemical Fant located n Poter Towns, Geaver County, Pennsyvania. The Pennsyvania
oro of he Falcon Pipeline is ppraximalely 45.5 mies i length. The pele crosses9
Penneyvania municpaltes which arealows. Charters Township, Mount PleasantTownship,
Robinson Townsii, North Fayette Township, Findiay Tounhip, Independence Tounshis,
Raccoon Tounshi, Potter Township, and Greene Township, Charters, Mount Pleasant, and
Robinson Townships are located in Washington County, Pennsylvania. North Fayette and Findlay
Townships are located in Allegheny County, Pennsylvania. Independence, Raccoon, Potter and
Greene Townships ae located in Beaver County, Penmeyharia. The Falcon Piping consisted of
a ota of 16 Horizontal Directional ri ses (HDDS) win re Commonwealth of Pennsyharia
According o SPLO's ariginl mein or he Shel Falcon Project, constuction and ee clearing
Commenced in January of 2015. Sie festoraon was fobe aking placeby th falof 2010leping
of2020, an th peinws fo have been commissioned nto seviceb te spingof2020,
6. On November 20,2076, Your Affan met with DEP offstocisuss the aforementioned refer.
Chie among he DEP concerns as that Shel and te sub-contractors fr the Shll aon Project
werenot folowing tn Inadvertent Return (IR) Plan which had been previously submited 0 the
DEP as a pre-condition for the DEP permits for the project. As partof the IR plan, Shell is required
10 off the DER of any IRs, regardless of te amount of lng fd ht surfaces. ALacertain IR
volume, Shel 5 required to nt ino DEP and cease ling operations ntl DEP approvesa e-
Start report. Thess conditions areas follows:
a An R of 200 gallons or grate, define 2 an upland area wilh 10 surface waters or
wetands,
5. AnIRof 50 gallonsor greater nan area with surface waters or wetlands
& Az or subsequent R of any quant no surfs waterso wetlands.
Work may not resume at ira location un tho DEP approves fh fest report. The DEP advised
nat hereview and approval process takes ampuhre rom 1102 weeks. DEP received formation
from former employees of the Falcon Project that work stoppages cost Shell approx. $40,000 per
ay. DEP offi explained ha the maximum ine amounts ha hy canassess on Shel or
Vilaions ons project ae nie amount of$10,000 por day. DEP oficils dicated hat here is
2 financial motive for Shell 1b in o.compance and gnor rework stoppage provisions
contained i he IR plan. The DEP was made aware ofseveral instances where Shel ale to
report underreported
Rs and DEP IR quantiles nan apparent alempt 020i work loppages which
ok equi azprovl resume work. Th DEP referenced one such incident onhe
Houston #1 HDD. Onlabout Octoberof201, there was an ongoing IR witha ot feta of pps:
43.000 gallons occurring avera percof 210 3weeks. DEP dealtvih an Envionmenta Lead
Inspector ntifeda rc DeLong, who niall reported nominal IR amounts. Delong
Giamisiely efred 0 th incident as a contol release oncewe st up containment” DEP
described DeLong a. argumentative, nol conrte, and repealed ri fo argue the ont” The
DEP sated fs incident was much moo seriou han epored, and would have esuleain awork
stoppage. according fo he IR plan. Ter is no language i h IR response pan which defines an
on-going IR as a “controlled release.” In addition, the DEP Bureauof Investigations (BO) was
contacted bya former Environmental Safty Gonsalant whows terminated rom ie Falcon
Project. The subject informed the DEP that Shell was under-reporting or failing to reports IRs to
20k mandatory shu coun proviins contained i he IR pan. DEP located suspect ets in the
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“Daly Environmental Logs’ fo the Houston #2 HODsisonthe folowing dates: Apr 24, 2019, Apr
25,2015, Ap 3, 2015. and ay 5, 2015. DEP explained hat the epor cated 04-24-3019
estimated an IRofappro. 150 gallons nan upland are. although pots ofthe R indicateda
lrger volume release, Shel stmote alowed ling o cone.ate,TheFurther, report dated 04.26.2010
contained a photo af an TR, bu Shell ci ot report an Rfo is dat. Th The Chel
Inspectors reports an IR. bt Shellidno sub a opr fof 1 confided othe DEPDEPthalpoint previous
ofShellcontactor tho Falcon Pipeline projec,IRsented a 8 Sean Larson,
haa sategy of unde-eporing voles so 2 ol 0 arouse DEP suspions and to
avoid wrk stoppages. Larson was he former HDD Coordnalo fo the Shell Falcon Poe, who
as terminal cnaboul September of 2016. DEP enfied th construction subconacio 3
Minnesota Limited LLC (MLO) as th co-partne wih Shel as lsd on DEP permits. The HDD sub
contacto was denied as afim known a Elingson Trenchless,
7. On December 5,201,YourAffant and DEP BO! teviewed Sean Amol Larson, he former
HDD Goordmate fo th Falcon Pipeline. Larson wosefeved fom i postion and release fom
is contract with Shell oabout September 16,2019. Larson indicated hata th HOD
Goordintor, i rele was 1 ait oor consult on ling plans, with speci. hands.on ection
of ighhrofi dls One ofthese ih prof il, the Heuston #6, was nat teBeaver Coury
Consevaton Distt (BCD) offices. He avis hat his HOD was taking place near re BCCD
ffces (a reguiairy ager), in an area pone a IRs n addin to wetand concams. Larson's
on elvaton changeof apros 8 foe fom th aAing
plan called for casing of the borehole, and placing
1 fo the bran. Thess soggestons
abermnear the exit sideofthe boreholedue to
Were ditegarded by Elngion Trenchless esulng nan IR on the Houson #0 HOD, ona
Sunday, onfabout dl 2015. According o Larson, 1 the event of an IR or LOC Efngaon
Trenchess wou 90on star-by pay ata ate of $40,000 pr ay. Wi such a provision, Larson
‘advised “...there was no motivation to do the right thing.” Larson stated that he attempted to take
proaive sops to prevent IR and LOC, In nsances where he proactive masros suggested
Ty Larson wee ignored, Larson argued hat Shell shoud not pa stand-by pay 1 Elingsan for
incidons whch wero deemed provable. As an example, Larson referenced the Houslon #11
HDD in which Elingaon ost over 1,200 galns, (LOG) and dnt report same un th olowing
day. As aesul Larson developed the Dal Fd clan Report (DFCR)to better ack uid
losses. Larson recalled ha he Falcon Pipeline was supposed tobe diferent hom previous
Pein prjects. that he Lead Envranmenta Inepacior (DeLong woud report decty 1 Shel
Rio HDD Load Inspect:wold repo the DEP Leen eerie fo ih pacts 25
* aelng the standard fo fo plplineconsructo. Larson claimed ha thro has been
oni undereporing fo he DEP wilh regard 10 Rs. Larson ached htho warmed Shll about
under-reporting on the project. When interacting with the DEP,Larsonwas given specific
Insuctions fom Doug Sct, the Shel Project Manager. Sot ok Lrson-..th lesswegive
rem (DEP) th beter fe are” Loson bakes he was ed fom ihe pret for bang (00
open and honest wih te DEP
6. On Dacamber 5, 2019, Your Affant and DEP BO! interviewed Era Lian Kasundr, a Regional
Projet Manager ina Senior pane Engineering fo Shell, Kuna stated tht sh fed an
eines complamt wih Shl alleging that ML was undertepring ui 0356 a the OEP. She
cae ht Inspector epersof volumes os rough Re whch were dacussed at he daly
leadership meetings were diferent han th 033 voumes which were eng reported to ho DEP.
Kasunra comended hat ML was ubmiing I 053 yoke eports ust under what woud
ine loop. The leadership meetings, which were pravouely nek alr1 were relocated Is
require a field visit from the DEP. After her ethics complaint, Kasundra explained “I wascutout of
14/46
nolonger invied to those mesings* According o Kasunda, the underreporting began on the
Fusion #1 HOD, whi theSCIQ IV HODwas on sandby. Sheadvise natshutdowns cost
Shell approx. $40,000 per day. Theseshutdowns eredelimentatoShel,bu due to angusge
inecoirac forthe pipeline, contractors received siand-oy pay proisians dung shutdown
peiods. HOD Inspectors Anthony Bourassa and Paul Lesen routinely reported IRs of 160
Gallons orLOGSof4800 galons, ust under DEP requirements foravor stoppage. Kasurira
201d tat Exc Dl ongwoud have been esporsle for weeklyreportspir totnHovston #1
10D. Delong aed 0subi theseweekly reports DeLongeventual submited a nal report
for ne Houston #1 HOD which indicated lid losses ofaprox. 46,000 galons. Delong claimed
{rere was af eastT Yau fuck on-5cene which ceancd up he fui because was an o-
goingspl. Kesundrabelieves tha DeLongwas responsivefort bulk ofnoneporingand
‘under-reportingtothe DEP. Shedescribed DeLong as ". .a negative personality, not aproblem
Soler
5. On March 10, 2020, YourAffant and DEP BO! interviewed aFran JacobChamber V,aformer
HDD Environmental Inspector, Ghamberinadvisedtha heworked onthe Falco Pipeline from
Sanuaryof 2018 10May , 2015. Chamberin's spouse, deified as aD'LayneCartewas also
employed on the pipeline a a HOD Envionmental Inspector.Intheevent ofa IR, the HOD
ity Inspector, the HOD Eniconmentl Inspector, and aremman rom the HODcontactor,
ElingsonTrenchless,would mest and determine fhe sizeof te IR and timate he volume. Al
patties had 0be nagreementconcerningthe number ofgalons. Cramberln statedthathe
Gaputed thevalu ofan IR at he SIO Il HODwhich was under-eportd on th ist dyof the
il, Ghamberin advise. fom that day onward. 1was give th cold shoulder rom te her
inspeciors.” Ghamberin was movedfo he Housion #2 HOD. Wie on the Houston #2 HOD,
Chamberin described aarge I which he csimate fobe 1600 gllons ormor. ThIR flowed
beneathth rig mals andoffthe misof disturbance (LOD). Chambetin aid herewere 2
vacuumtucks on sie llday aemping fo conti te release.According Chamber, a HOD
inspector named Tom Larson respondedto the site and told him that*...Sean (Larson) said to
make 75gallons.” Whenasked specifcaly “whowereth offlalsresponsidefo under
reportingofRstotheDEP.” Chamberin replied: The HDD Environmental LeadEric DeLong and
the HDD Utiy Lead Sean Larson” Chamberin confronted Delong once regarding under.
teporing 0he DEP, and Delong responded: Thatwas si Sean.” Chamber indicated he had
Knowiedge of unreported IRsWich occured at the Houston #2HODanfabout Apr 75°, 2019
Shell reported an mil IR a he Houston 5, ut Chamber advised ere were 2 103 scion!
Rs wienocctted on he same date. Theseadditonal IRs were not 16pored 0116 DEP.
Chamberin aise hat the motivation founde-eporing dons 0avoidshutdowns, ic
costsShell meandmoney. Chamberin and Gari were released fom the pipelineonabout May
5.2019.
10, On May 14,2020,Agentsconducted asecond infeviewwith Sean ATold Larson, Larson advised
{na fan Roccurred, he Enironmental HDD Inspector ad heauhortyto determine th volume
ofth release and i work stoppage was require. here as a isp regarding tr sizeof
therelease, te Envicnmental HOD Inspector, The HDD Coordinator(Larson) anda
Tepresentaive ofElingson Trenchless wouki have t agree on he zeof th spl. Larson
indicatedfattherewas an unspoken understanding amonge theHOD inspectors fominimize the
lumeof eeasebecause would resull ness oun mewhi wling fo DEP (052 they
Cou resume dling.He explained that when DougScocame onasthe new Project
anager, ringswentbad. Larsonrecalledone speciincidentpro 0 is feminatonwhen
Doug Scottwarmed him: 1m it Gong le you havethe DEP jecpardze ts project Larson
15/4
tated he was responsible for te reporting of IRs and LOCto the DEP. Tre HOD Environmental
Reports were maintained by DeLong. DeLong ha the indidual HDD Environmental Inspectors
send ei reports fo DeLong lecrrical via Drop-Box. Afer submital0 DeLong, the reports
were vansfrre to anther Drop-Box, so the inspecors were unable to access or examine hei
reports ater submits to DeLong. When asked f DeLong evr nsiructed nspectrsto”. dont
put anything bad in reports”, Larson responded: Yeah, | heard him say that al the time. Tha, and
Keep your opinionsoutofyour reports”
11. On July 15, 2020, Agents interviewed aThomas Lowell Larson, who was employed as a HDD
Inspector on the Falcon Pipeline fom January of2019toOctober 10, 2019. Larson advised that
is brother, Sean Larson was responsiefor reporting IRs and LOCs othe DEP. In addition to
the DEP, Larson would havetonotify Eric DeLong, the Lead Environmental Inspector, and the
Construction Manager, Greg Wikon, According to Larson, Ellingson Trenchless id care about
pls. If here was mu inside the LOD, twas considered okay. Just cean tp. Larson advised
that Ellingson would drill until there was a problem due to a stand-by pay provision, which allowed:
them t be paid the whole time, whether hey were drling o not. Larson theorized tat is pay
structure provided no incentiveto do things the ight way. Larson stated tha. Elingson dnt
follow the IR Plan. They thought twas ajoke. They dict achere tot even afer Sean sht them
oun several times. Larson maintained tha since Elingson was nct folowing the R Plan, Shell
id not have to py stand-by pay. Larson believed that shutdowns dueto IRs andlor LOCS were
preventabe,if Ellingson had been prosctive about problem solving.
12. On duly 16, 2020 Your Affant spoke with a Susan Dayne Carle via telephone. A olowp in
person nterview wit Carle was conducted by Agents on July 24, 2020. Carte reports hat
iia she and her spouse, Frank Chamber IV were welcomed on the Falcon igeine. The
Lead Environmental Inspecior, Eric DeLong, sates .we need you on tis projec. You and
Frank have the most experience here According to Carte, most of the other Environmental
Inspectors had no experince with HOD. Carte recaled several Rs on the plline which
company offcils attempted to minimize. Carte eferenced the Houston#7 HOD, and stated there
wes an IR which occurred song Route 576 in Imperial, PA. They shutdown he HDD aftr an IR
of approx. 2,000 gallons went uncer the roadway and nto underground caves. Carte advised
he was with another Inspecor, dentfied a5 a Keifer Tabaka on this date. Tabaka phoned Sean
Larson to report th spill. Carle could only hear what Tabaka sad on the phone call. Tabak
state: “Delayne's next to me. t can't be 50 galns.” Carte tale that fom what sh personally
observed, was obviously more than 50 gallons, twas wel over 00 gallons. Later his dat, she
received a tex! rom Tabaka which read". put at 150 galons” referring to the IR. When asked
abouthediscrepancy Inthe oti, (2,000 gallon estimate versus what sh personally cbserved at
over 300 gallons) Carte explained that tere wasa sris of IRs hat day. She observed anther
IRactoss the highway a te HDD exit pin. She sate tha an unknown laborer communicated
rely to her we've got a cal of 7 IRs." DeLong directed hero remain at th entrance o the
HDD sit because"... Gin van me to see the sizeof the IR. From what coud see rom the
entance, it went for the eirance to he pond, ntoa wetland, over aseries of rocks, to the her
sideof the wetland, and 0 a sream.” DeLong subsequently called remediation company to
he scene to clean tp. According o Care, they Installed a curtain in the pond o top the
How, butt was instal backwards, he wong ay. It had tobe reinstalied.” DeLong summoned
"brand new Inspector dented ss 3 Jacob Rieve to document th spl. Cart advised that ne
Conslruction Manager Greg Wison set th tone forth prject and authored the ‘Dal Acton
Report” Wisonlef this report nentonal vague, and did not call out problems in re report. As
an example, Care referenced the series of IR on the Houston #7 HDD, which occured onabout
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05-08:2015. In the Day Action Report forth date, Wilson advised". not 0 go fo he exit side of
Houston #7." Carte suspects they ic want acional persons observing the mulileIRs a hat
locaton.
13. On Seplember 23, 2020, Your Affant interviewed a Water Quality Specialist (WQS) witrin the
BureatofWaterways and Wetands at the DEP SWRO. The WQS stated tht the DEP was
unawareofproblems on the Falcon Project unt te end of Jy, possibly early August f 2019
During tis time, a Supervisorin the Program nolfied the WQS ofa“wisteblower” complaint
fiedbyan Environmental Inspector. The complainant, dentfied as a Frank Chamberin, had
come forward fo allege underreporting and non-eporting of Rsfo DEP an the pipeline.
Chamberin had text messages, documents, and pholos. As a res, The Program Supervisor
requested additional documentation from Shell, to include daily and weekly logs from the
company. The WQS advise that the company must submit weekly reports to tha DEP, but the
submissionof daly reports inot compulsory, nless the DEP requesis such information. The
WQS note tha the DEP had concerns ith several dates associated with the Hotton #2 HOD
site n patular. The datesofconcern and a summon of the cumstances surouning each
ate are as follows:
a. On April 24,2019, Chamberlin had photosofanIR. Itwas reported to the DEPat one-
Hundred and ity gallons (150 gis). From ireviewof photographs, the DEP fet twas
larger in volume, but the IR had been cleaned up.
b. On Api 25, 2019, there were pholos of an IR. No nalifcation was made to the DEP.
The daly report indicated a clean-up. The IR appeared again on the same date. The
sit was cleaned again, bt as not reported o the DEP.
G. On Apri 30, 2019, there werephotosof an IR. The DEP was not nafied, nord the
event appearin the weekly summation report
4. On May, 2019, Chamberlin provided a photo of an IR on the driling pad. The spi
appears t be coming up trough th timber matting. DEP was nol noted. Tne daily
{eport to DEP was not provided until on/about December 19, 2019, afera request fiom
DEP. Shell describes the spill 2s a punchiout release, which was confined othe bore-
box...” They describe the release as only severly.five gallons (75 Gal.) and a clean-up
of an IR on the pad.
“The WQS went on to state that the “weekly report”is a report*...of anything IR related.” These
eports are supposed to include a description ofthe IR, cumulative amount, containment measures,
How the materials were recovered, where twes disposed of preventative measures taken before
he dil, and photos depicting the event. These reports re intended to bo@ summary ofevents
Which s submited ona weekly basis. The “fnl repo is submited upon the completionofa il.
‘Shel failed to provide these weekly reportsas required, but submited al th reports upon the
Completion of the ii. Oniabout November 8, 2019, the DEP received a sri of weekly reports
covering the perio from 1010812020 to 11/06/2020. Thi report was submited by the
Environmental Load, Eric DeLong. These reports dealt with another ri entfied as Houston #1
HDD. The WQS advised that DeLong had notified DEP of an ntl IR of approx. one-hundred
gallon (100 gas). He (DeLong) reported wo (2) IRs very close together on/about October 4,
2016, The IRs were reportedatforty-six gallon (46 gas.) and sixty-seven gallos (6 gals.) for a
combined totalofapprox. one-hundred and fourteen gallons (114 gals.) Roughly one morih ater,
onlabout November 8, 2019, in the “nal report” submission, DeLong reported theIRs ialed
approx. ory-eight thousand gallon (48,000 gals) and thirteen thousand gallons (13,000 Gals.)
respectively. Eric Delong sent these reports {othe DEP on/about November 9°, 2019, afer th dil
was fished.
17/4%
Accordingto the WS, the IR plan required DEP notification on every IR. In an upland ar, if the
spilvas less thantwo hundred (200) gallons, nlfication was required, but there was no work
stoppage. Ifthe spl was greater than two-hundred (200) gallons, threwould be DEP notfcaton.
a work stoppage for clean-up, and writen approval fiom DEP to resume work. There vas an n-
person meeting ith Shell wich tok place oniabout November 11%, 2019. DEP addressed
previous IRs and questioned why they weren' being noid un aferth fact. Delong atempted
fo argue the point that if an IR happens in the same spot hats expected. Its notan IR
anymore, itsacontroled release.” The WQS had never heard ths term used befor, and stated t
oes not comport wilh DEP's definionofan inadvertent efun. DEP dfines an R as. when
ling mud comes to the surface.” DeLong calmed the iiing fuids were sucked vp bya
Vacuum track on scena.” The WQS advised that Shell never proposed revision to the IR pian for
a“controlled release”, nor would such a provision have been approvedby the DEP. The WQS
explained that the permit os not alow for Rs{o happen. The IR pan spells out the steps the
company must aketo alviae the R, to include further preventalive measures. The WS gave.
examples of preventative measures, including: te reductionofpressure, lacing loting materialsthe
inthepathof te il, clearing equipment mare frequently, or casing the ri he IR s close to
surface, Shel was supposed 0 take such preventative messures, nsead of merely alowing the
R10 come 0the surface. As aresult, DEP sent an R reporting clarification letterfo Shell onabout
November 15, 2016. The DEP received Shells espanse i writing via e-mail onlabout Decernber
69, 2019. The WQS advised rat Shell was very vocal about shutdowns costing money. The
WHOS actised that after DEP shutdown, the process woud take about aweeko 501 get the
re-start order. TheWQS recalda conversation with £c DeLong atthe SCIO IV il sie, which
was being riled from August to November, 2019 in Beaver County, PA where DeLong tod the
WS that shutdovins cos the company fory-ousand dolars 540,000) per day. The il along
he SCIO IV was shutdownfo approx. three (3) weeks The WGS suspects. hat the company
(Shell andlor Elingson Trenchless) madea nancial decisionto continueo il and no report IRS
Itwas more beneficial to keep going and face the penalties.” The WQS spoke with he former HOD
Coordinator Sean Larson aftr is ring when he explaineda spread shee that he had developed
fo rack losses of dling mud. In tis meeting, Larson expressed his fustaton with Eingson
Trenchiessfo ...yabaling IRs, and not measuring LOC. In addiion, they were not folowing the #2
IR plan, nor string to Larson's directions” The WQS conducted an inspection a the Houston of
HOD sts on/about August 26, 2018. The WS examined th IR plan, which called forthe use
meters to measure the amount of mud discharge on sie. During theiheinspection, te WS noted
ihe workers went ahead an stated inout the required melers, workers were unaware hey
needed therm.” They subseauently had a LOG which required a shutdown. When the WS
Quizzed the workers on se, .. the workers on the iil did know the IR pan.” Larson
Subsequenty shut the project down o re-rain Elngson Trenchless employees ontheIR pan.
When the WQS learned tnt Larson had bean fred, she was tld that. he los is temper and had
anger issues.” The WQS advised that there was disagreement with Shell and the DEP over what
“significant LOC" meantin the IR pan. Shell wantedth fem “sigifcant 10 beset al ten-housand
(10,000) gallons. DEP decided that “significant” would be five-thousand (5,000) gallons. The five
ousand (5000) gallon thresh-hold for a significant LOC was adopted by the DEP in the revised IR
pian. The WOS received information from Frank Chamber that. there was a culture of Keeping
IR low...” on the Falcon Project
14. On September 23,2020, Your Aan interviewed a Supervisor itn the Bureauof Waterways
and Wetlands Program atthe DEP SWRO. This Supervisor has worked on 3 mor pipelinesthe
during the course of their employmentathe DEP, to include ththe Mariner Eas#2 Pipeline,
Revolution Pipeline, and th Falcon Pipeina. As i rlatato Falcon Pipeline, he supervisor
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Inicald that ShhDErecoedsuswit ransparency, which was aconor. Thefistsamps, arose in
ot 12015, when Chamber a wal.pow! amp fom ome rofect non
Known4 Frank Chambori. ca onward alega he under epring andor
Teporingof Re on ne rfect spell Washingion#2County, A. The compat whichwas
i he Howson HOD.GlyTheHouston
Gamba lodged wihMay62015.DEThedeaSuperiorxplanod #2 HDD
ci om Meno at opts fen required fo be
Ssbmite dta requosed. Weekly pots ra qused 0bo simi
heDEP.unlessspecial
The Supenisor
DEP. submited
othaeports subsequently compere he brmaton rowed by Chamberno
ine b Shel, on ound ctepanis nh eporing. A a esl he
Seperuaos quested Doty HDD pots om Sl. In onof ces eps, dled avout Ao
245 3016, Shel rapredan of nehndred and ly(150) Galoto ah spd fea. ns
instance, Shell could stop driling,cleanthe IR, and resume diling. If the IR is more than two-
Red 200) gakons, anes ele stp. Chamber advice I was role han ane
Rndred ad fy (160 gallon and submited phtos a poe Th Supers oovosd 14
foot 1 foro proto th st vm of hI. OmaboutAp 25 ard 26,2016
Chambers fepor Inikate ht he aarementoned IR rocceare ne folowing do. Ths IR
vos novelrepens the OEP. Chamber proved ods fom Buco Barger can ht
Ine IR contimed: Week apo souks ave sed hth tn 1continues. Thoporso
iewok dd nt. Th Second and subsequent 17s onAor 6ad20 wero over eprtd10
ihe DEP. TheSuperior aise ttn reports svpatdb Shll ro lo, n ht Weck
Teper th addioal Rs. For hs Apr 24 201 dl, OEP hs of oseass
fram Ee DeLong. whch red Soa say 1o Kaa or 200 galons.Keepup Tholos dese an
eTve 30 galonsean tiand recoouting DEP £0 DoLord 0spons: a eyiha nee 0
Keep coun Toe Super exlaned hl he ook at Ie, and
becounted. 17k Thre8 iolaton oh workplan and the pers” sch 30gallo wasnever
Tepored101hoDEP. 3 nowork Soppage prowlon of 2 o subsequent IRs nan upland
rea ony awn o wale ten. 1an stars and cops for ow yes anow
Fon contin, 3 te same I ar i vem shodbe added 10 0 ola volume. The
Superior advised ha is cao, eh Shoud have shtdow and oi.The wale fh sat
order Toependactaies rt Smtdoun ypclTless as awoo rSupasor Toa
aivood ht he rm manage elses anlr-eoirted oot aduskym. The
Superson of be pion date pat Shll rete 10 fous thl noporing bahar”
ek estonsbl oering was May oh 2015, hg Howson #2HD.TopoOnata hedate, are
ve on in th primate of 1 toan upland re. The week oh DEP.ayDu 107
p, be Ion May 5°eprint
2076tferences clanLarsonwasresponsible 015wa netTepredSuperior
i i rm, Sonloonhewas andor optingonon fr th DEP, The The soe hat
theOEP,
newasspan
Superator plive he ws 10d 0m profec.-Ocove epring 1 Ie
say Novber Lain
Seesaqsonty comacia 0Supene mmedately aer Ne ing > dss h pret an his
oncom wil same. AN meetin, hey docu LOGS. Tha pla,DEP-any Wichwascantages os upon
oy bon partes, deatobo ht Shs Tred10.040 op and patsth (50
Shah wanted-Sgnica guanont as gators. DEP amu al 000
Gabon ahead enuent a gher vom on Gebycase xara. Larendoused a
rend sheet ack losses, and expandsame oe DEP. Larson od the OEP hth was
red veuauee of esti. howes accuseof yelling and using ovsconientration
Urea suspected wesDEPerly prox. and he rd oason behind i a low wa omloee.
id
becovte hewont 1h nd shied he cotraclrwas nt rng regarding racking ot a“snl
love ad loppgnewihsce shold
he cools noted th plan, The DEP Supousor sont
ou nda 50 sna. DUG 1 SHU Gow PipesWere 5.
19/4
educated on the IR pian. the yes of Shel Larson was instrumental in geting the projectsh
‘down. This shut-down lasted two (2) weeks. Larson was fired three (3) to four (4) weeks
nereater. Larson expressed is rustation hat Efingson Trenchiess was ro lowing fe 1}
plan. Shel normed the Superior rat shut-down costs thecompany appro. Wenty-ve
thousand dollars ($25,000)perday. The Clean Streams Law allows a maximum penalty of ten-
nousand dollars (510.000) per Gay. The Supervisor reasoned ra fs cheaper forShellnot to
comply wih Ie aw and coninu to dil. The Supenisor suspects tatThesmear from Shel made
{no tnancal decison foal and wal and se f hey got caught.” Supervisor added that
without Frank Cramer's complain, the DEP would never have known.” SomeoneErat Shell
“looked a the cot versus the bene. In mast instances, we (OEP) dot catch them.”
Delon took ove eporing othe DEP afer Larson was ed. Delong was to conact he DEP in
the case of an IR, and submit weekly reports to the DEP. The Supervisor advised they would
Speak wih Shll via conference cals every wo (2) weeksto discuss te status of te project. Tre
Supervisor explained rat ring shut dows, DeLong wouki contact me lle times er ey.”
The Supervise advised {here was a ‘g1oss viion of the pla” which accured on the Hovston
HDD si whieh began onabott September 30, 2015. An Rto an upland area wes reported as
ne-hundred (100) gallons on 09302010. The IR was subsequenty cleaned and ring
Tesumed. Delong fed to submit ih weekly reports rom October 7, 2018 uni the OEP
fequested same oniabout October 31, 2019. In the repos rey submited afler-te fac, the
fepors indicated he IR as appro. fory-<ight thousand (46.000) gallons in ial over te course
fhe Gil. Th IRs wre not reported, here as no shutdown, and thy fad o maintain ‘best
management pracices” n contammont. DEPwashaunder a mesting wi Shellwers tr term ‘ontoled
Telase’ was coined by tn company. This Eric Dong’ tenure 5 the person
fesponsile for 1op0ring fo ne DEP. The Supervisor subseauenty sent out a clrfcaton e-mail,
indicating tata controled release was i factan IR. The Supenisr tated tht Heather
Srowstc, fom AE Comm. was one of he Project Managers empioyed by Shel. Brewster
{espondedto the Supervisor's emai, attemptingto xpai a ‘managed release” andlor
mantating an IR. The Supeniso noted ha is ws the rst me taking such pio, and
rat Shell Knew exactly what an IR was. The Supervisor cussed the R ian for the proect
The IR lan oxpiins lhe HOD aril, geclgiel formations, protocis for IRs and LCs, time
rms, and precautions an potecions n pace{0prev Rs and LOCs. The pian's for
Cubsequenty reviewed dutng tn permiing process. Shell and 1s conracors re responsible
cducating hr amloyees oneae the lan, and ensuring adherence f the lan. The IR lan or re
Shot Faldon want ough af eight (3) evsians. One of he topic of contentionon he lan
was measuring an IF, which he Supenisr described a5 vague". The DEP sugested ra ne IR
oe mcasured wilha measuring ape, using the formula engi x vid x Septo determine an
amountinvolume. The Supervisor sated {atthe DEP would have approved ancrer
Tevionoftn I plan with language smiar to a ‘contained or managed release” The Spervisor
planed tht al Rs shotb tepid to the DEP, regardless of uanty. The reasoning bering
iwasbecause the DEPwould goou and inspect an Rwhen reported” The Superisr
Sate that tne DEP issued seven 7) NOV on the Snell Falcon1.8 Pipeline. As example, she nofed
{nat Shell Gt stabize two (2) mies of pipeline righ of vay, ig,mies of which ra ough sip-
prone arcas. Shel fale fo etal recording equipment on al fled oreport Rs, and failed
To bmi weskly R report on me. She described hese NOVS 2 .more egregious han he
ater poles.”
15. On March 17, 2021, Eric Scat DeLong tesa before the 46°Investigating Grand ur, located in
Piourah, PA. Delong has been invoed with tne Oil & Gas IndustyPols since to2011
Delong sare in he nue side moved 10 safety consutant wrk, and anationsa
20/46
Environmental nspectin(s). Ho has worked numerous pipeline projectsinseveral states
DeLong spoke about the Hinerant nature of pipe work, stating: once the projects complete,
Jou move along to another company. Mary Gerschafski rom Shel originally contacted him about
working a an Environmental Inspector (=) on the Shel Falcon Projet. DeLong indicate he was.
not intrested ia regular E1 posiion, but had been an Environmental Lead. Ho suggested...
could help ith reporting and suf ie hat.” DeLong was subsequently hired 3s the Lead
Environmental Inspector bya thir-party provider known as Giobal Edge. Gerschefsi alowed
DeLong to form is own team of Environmental Inspectors. According to DeLong, Es check
the ob ses, heck containmens, leaks, and spls. They woud mont the right of way along the
dling pth, heck resources, road crossings, steams, wetlands, environmental compliance wth
ECD (envionmental control devices) in them sic) areas, stuf that. Daly reporing.” DeLong
described his dues s check in with my field staff, ook overth dai reports, ou ob sites,
atend moming meetings daily meetings, management meetings, field inspections, timesheets.”
Delong iferentiated Eis . 25 the environmental inspectors were there for environmental
compliance, while HOD Inspectors were there for more of th technica knowiedge of what was
going on wih th dling equipment and the functions of that equipment. They wre more
knowledgeable in th dling process, where environmental s more ut on the ground monitoring
out resources and ight of ways.” DeLong dented the Lead ofthe HOD Inspectors as a Lan.
Greenwat. Sean Larson had been the nial Lead HOD Inspecor, bu he was replace by
Greenwalt_ DeLong fesiied "| would work hand in hand with Sean and Lane every day, and his
inspecion taf would work hand in hand every day wih the inspectors on their ste” Sean Larson
was responsible for reporting IRs and LOC from the beginning of the projec uti September
2016. All the inspectors noted IRs i thei diy reports. The LOG reports came from the HOD.
Inspecor. Both sets of Inspeclors reported IRs and LOG. Onca Sean lft the project, DeLong
advised hey pushed me info th role of eporting to the agencies that information. DeLong
was subsequenty given the responsibiltyofreporing IRs and LOCsfo he DEP. In heeventof
anR, the riers would top immediately. The inspector, along with the contactor, Would go out,
contain, and evaluate the size of the IR. the i was reported up to Sean. My inspector et me
Know, hey tis is how much it” DeLong would respond to IRs on some occasions, i instances
where a resource was impactedo when DEP would respond to the locaton. DeLong stated that
the process used for measuring the volume of IRs was typically a visual estimation; sometimes
hey would bepacedoff. to give the best estimate possible.” Later in the project DEP requested
he IR be measured with measuring tapes. Inthe event of an IR, Es woul go o the sit for
inspeciion photos, and documentation. In the event of an LOC, Els would wal the bore path, and
perform checks for impactsto reams, wetlands, and roads. Drones were used when theywere
avalable. DeLong reported o Mary Gerschelski fom Shell HSSE. DeLong stated hat Larson
and ater Greenwal report 0 the Construction Manager (a thir-pary hire),ScottAdams, a
Shel Engineer, and Eric Skonberg, the HOD Speciast. DeLong identified a Ken Davidson as
being the HSSEManageratthe sie. Davidson was in chargeof ste safety, security, and would
be responsible for requesting drones fr IRs or monflring th rightofays for might hit wor. If
there was a concer within is work group or on ste, DeLong would goto Mary Geshe. If
there was a compliance ssue, Gerschefsi fold DeLong to contact Heather Brewster or Scott
Adams. Some minor compliance issues would be handled wih Sean Larson or Lane Greet,
sich as which nspeclors would be assigned to a particular se. DeLong estimated that 50% of
His time vias spent in the office, and 50% of histimewas in th field. A workday was typically 12
Hours. DeLong's report would be sent to Kathy Gill at Global Edge. Gli would subsequently
upload tem to Shels SharePoint system. DeLong stated: | tin they cameto me and just put
them in a group e-mail and forwarded them.” Kathy Gile lf the project, and Mery Gerschafski
directed Del ong to get SharePoint access to upload reports. Delong talked to his nspectors
21/46
llth i on he phon, et message, grup txt messages” Delong was ane in he IR
plan. He stated: “We went over it with Mary, Scott Adams, Eric Skonberg, Sean Larson, Heather
Tesponaiies of pe apes. Doon sad Sean Lipson, Wry. and ahr versresponsble
Brewster". DeLong statedthatthe meeting reviewed reporting requirements and the
fo aig the ming andwahin he nopects ough eve ieof Plan DeLong
Tecaed
Tear dlingthw shoudolindy
roves onip,vrsof8heContained
1 Pan.oDoor
un headwid
proper tntame
Raion Pov ers
Seen me. DeLong $5 th ean or 8 LOG or rjc nd boo capes at 5000
workout
had a-eennica betweenDelong Laren ndhl3an EP.
Seannated nly a
Salons,
Teporablamount oawhch
on a3eement LOG was amount I:of ovr 200
Gaon, ovr 50 galon a wetand of ould th LOD of ROW ree a esta ror fom he
DE to alow dling ress. When ssked how org restart eps ake Dong epic:
varied, Somolines coupl dys, semaines aewes Datong aed at
convacorrows wero eng pad gare of whever ok ling was acing Delong
avid ntshatdows co Shell auners fon $500010850000 pt day. DeLong ned
nese mummers fom pot the ol bt ns ort fhesceracyof he fires. Delong
recalls sharing these figures with a DEP employee in the field. DeLong testified that until 09/2019,
Ravesomal reportor Laren when shed. Daan Severin Ses Larson, Tom Lar
Sean Larson was responsiblefor sending weekly IR reports to the DEP. Delong advised he may
and aul Loitoon a hy all camo fom healing nat. very knowiedgeai DeLong
Ste hat is pcos called Hever mo hrs vs an 2. Door wd lal ass. fs
Rn IF) impacting esoutoes nh gh of way DeLong was aod abot a 1 which
nessage onhe D4242516.
Gecurad DeLongsetremembered
sot cain: Sean word opme ndon unr 10038DeLongThatwastucksn
asked bout a xtThe
ge ve.
Toco 43 uk cou tg ot pat Mimosa lr oo cess. Tren ar can 0p
ow Wilke th et heer. Then Davewi empl up ou ay. Tht ht has pee
Salt” Rathr ham an ampfo mins fa I. DeLong sad so ke andr 100 gals a5
ee hs contort der 100 gos ofacme net ve he It wilt cleaning 1 a
Gran to sscapacontalnmat hats pu place Lonacknowiaged hat volume
Tapered
{ea franleased
volum waahaldependent
shld havaon been
wheter
repre.7c Dion
was vacuumed
was askedupnether
oc ht vaswasis1
ncersianding at ring coud connie ig a 700mg 1. scl a all he we 3
Vecaumee
nates a esse un He Slotaoe ratsov wheriawe wire
a miei 4onwert501comamant
par tet ce and conned,
was bon
Teraveh ing Soul comin pr Sls Guan DeLong eed athandpl reese
ht dono nape aan, DeLong acknowledged nt wos thr rower ry
(IR) is not supposed to happen. He agreed that Step #2 is to stop the release then ensure
Sersneloh Sean Liteon and ane Groawah who repose at Ging oud conn wha
ranging
lace whanthaho eviowed
Detongthclaimed
1 Plan. etDeLong
not nrpeatoncocanngconinang
was unable fo recll vs meetin n wind aws1
Vining Plan When ask ‘Was nis someting Shll reed and pasa onfoyou?”
Delong ep: vos DeLongwas shown a sereof om Chamber where harper
questioned
n orinlhy, rd worehe3000foovacuuming
conn aingoy imritly.
when nF wasDekong
comingespons
ot fhwinsama loaton
a hank sou
nv ui Sean sad morning, as on as hy Keeupwl ad says unr 200
gallons.” DeLong explained his response by testifying, “I believe that Sean had the conversation
itv pectin at and $21 I: Corti with caramen and stays ont 200
Goons ofa ntaccamulton.
Betoncoud eel 1 werkt hey ul th cone ring socored
1 she. Goons th dooe a 65095 nt conament”
fh content h was
22(46
teringtwas.
oni oe utaround
a hebhot olofth gk. ke1 Dongseed
oe thre was 1
eini
rounder Delong ted hrters ds cpl ome’shot Chamber
oe vile ate sow.madeBoon stedhehth01243015 wosDt epaedio h bothe
OEP
DeLong said the contractor's complaint was that he (Chamberlin) wasn't giving them enough time:
Sean Larson 4
Ifom 124.2013war DeLong 3apo
soningbased on lmao DEP. Or 4.25213,
ecowestreps
fon Chamba, rps Delon
ots
Hoven rein. iornaion
etong wok
dd not nest
och 0 hi
anRnG432010 01 05052016 DE
Chamba bec
Devo: vesa mma reo whst brome evoted oa OEP. 28
reported a75 gallon IRon the right-of-way (ROW) when they were pulling pipe. According to
as ger 20 gallons anon he ROW. Dogwero 0dss

F171 Delong sted hther wr cngin 5s which wre epaed a 100lens ls 0 ge onbeHouoen
Shalant
nd etvaroeDEP iei.tod Hi rt olin
dite ttthcotat
pcr wheehtcman
she 4 ee alyome
of 0 St volome
otreso ar tesonreat iy ot eyent.DeLong ses
ekg
malereports
rsa was ing
easingSoren.
neook a egos. ev hom Gertous snp. mit DoLonTe OE vesean
rd
Topo
i n Sathm
venine 1e oeoInnit.
outi 1. Seah
Delon Soddiet
wesovh DEP1 onsrsmais
he who asean
manatotzaor otondibesarte
Devoaesmn elon ee aco ponsave osenn ESgE esa 2svat
in
epring ee
is2nd LOG. Delon bscasertyShonda asin wihha DEP 112075 rms
eli En a ant Roe wel ape wa ER
where the Houston #1 HDD was discussed in detail. DeLong recalled Casey Talento jumping in
EL
ansseetoy
hs mesinginiatBrows
DEP eryGarcon S00 Larson man pro
16.0nRAYS
une 15,2022,YourAlfatvieved Spr aHeather Lyn Srowtr, a Seiorioipr Pret anagerd
enan
PtsSera av.Sr wl partes
Gareon tog ro Bepaoviol
EngrSry ore Sr nnFoon lt
mama rove a es tomboy ears tut
Project. The scope of Brewster's work on the Shell Falcon Project was as follows: (1) anti-
ramonERE
amie ues.rev ot rosparen
at etn oot fing wihContant
FadedonoEnayEe eatery
Pro,
rtscomodo
oneness compen ok hon
(ohm espns: {eosaterretolporn,
sonore, shou HOD oaton enrol (2 002
em
ere oe Seve
sateomadonrs. anewasconto
Browser absobt rover,
eves sh osnedvarnt
scaloatve
races main Solar Elina enon. Wewood skwha hehatshwold ob oh
roti soln
Sheswey wrta ves, wes Io 4s
ig vere. Fetewe proces Shexpand
HOD ne vd re wo tonTan
es gotpenrta relesve,ne ea
and ye | wd poianc: Whensksabo
ons
23/4
Scott, the Project Manager for Shell Falcon, Scott Wooten, the Land Manager, and to a lesser
‘extent, Ken Davidson from Health, Safety, and Environmental (HSSE). She believed that Doug
‘Scott would make decisions regarding losses of circulation (LOCs) and IRs, and the subsequent
ptr Sot TE Sra
HDD sous Ion Re or LOGS, who woul ve th um author over (hse Shalone
‘and Brewster replied “Doug Scott” In the event of an IR or LOC requiring a work stoppage,
rower advised hat hose decison were made byth consucion te. por th pon.
Brower atvioed a vowoull av beer ais food becavee so hod >
iE) oot ntheI ooh
gain on reya arama Ada rreatTw ot ep arA
responsibilities in such an event: (1) to notify nearby well owners of a potential water impact(s),
TE. raerooEre OAT

sentiothe DEP. DEP approval of iere.sar potwas necessay ( esr HDD cis.
Sr te A To eet a Bat
bot manager racios (MPa)wiespace. She eked on he arsonand
cifoaions nuded tems Sun as sit socks a hay hales, When asked about he use fret.
sedimentation (E &S) plans to update the BMPs for these re-start reports. The E& S
wells on the project, Brewster replied: “They were discussed, but were not practiced to the best of
my knowlde: Wha asked about he erations wih Ei DeLong. Brower replied Ho was
ihe HOD Eveonmental spear. Hoknow what was dong. When asked shewa
Teceing any fob om Sv on te prfet Cravetr stata: Yes Th rlware king
longer. Traywere longer ra experi” Evewsir reheated a ot of recon was
wih Doug Set but ot sh ale dol with cotAdare -.-wn wast overall Prof
anager fom Houston, TX. They wereth most concerned wih work stoppages.” Far of her
Tesponabilies wast facialcommricaton between Snell and the DEP Brewster vena
became the perso that wou lay questions andlor oman i the DEP. Brewster sated
rt she was rr wih dscusdons wi he DEP on changing te language in Ik Pian fom
“Sgifcan
recalealndingLOCo aLOR" to assigning
meeting wih DEPaspecie
wi ooknumer ace i value nfs
November ofvou.
of2010 Eveuster
fogarding IR
reporting, instrumentation (water meters), and LOC amounts. Mary Gerschefski from Shell was
TR amonrta which wre bag ome ware nt sll rowel sunabe fo rec Er
present. The main focusofthe meeting was the DEP's concern(s) with IR reporting, inthat *...the
Delong wa ls mesing. Er DeLong. shoud have been repring (hose loses as ey

Da
Der. rewaer calmed
hate ha DEP
DeLong
ah iddownhot hesonprec.
em oh: twaswih1059
Thi ecting hh00kcl
‘wereoccurring.” Delong had the reports, but for unknown reasons, failedtosend themtothe
She reported he DEP pace

Sop. one (1) weekafer fh worksoppate, end was veraconeranosol. DEP wes
ConcordthehatR heya
fede reports” ntBrowse
cerecalledrepos anGerschfsd,
nat Mary tt he I Doug
was conning
Scot, SctunlAdar,
DEP and
Goer Tolotower on hecan aclion fo er Wire asker Brewer sated hat Ec belong
an ane Great fom Eingaon Trenchless ..wers most Hl a1 he mestng, bt ca’ 50
hehundredperoat (100%) ure When asked, rewstrndate tat ffl fom re She
DEP concam. At is meen, awater vie hy doussed ro om managed robes
Falcon Project had a *pre-meeting” the day prior to meeting with DEP to discuss a response to
Poconding o Erowstn, vc Datong cove oe fom anaged leas’ o desi an IR

hic 1s continuing o cet, wis EWP in lace, and ava uch on scone contanng he sil
When asked, rowstr seed. had not hard efor befor, ot |was ayoothe
parmiting se. Tis wasmy rt me on theconsucion side Delon sc Hea bY
Sesebing 26 a1 ay sana, Tos 8commen racic. Evans tendo seemed
a
24/4
Gerschets, Doug Sot Scott Adams, Casey Talano, Eric DeLong, and Lane Greerwall. When
asked fh form managed releasewas ound anywhere in he approved IR Pla by Hull
Brewster responded: No. is nt In accordance wi th plan” When asked whose ob was to
make ceria employees on the Shell Falon Pipeline understood the Pian, Brewer indicated
na hte was an envonmeial compliance checklist, and hat was one componentof
Inspections, which ould havobeen partof Casey Talent's responsi.Brewsteradvised
natAECOM didnotprovkleany anvkonmenial rainingof IR raining on hs project. Brewster
tated tht ere wre questons abot the IR lan, Ec DeLong wuld conact hr wih
questions. Prior to DeLong, Sean Larson would “courtesy copy (cc)" heron documents
Gecasonaly,butno al he ime, according fo Brewster. Whenasked aboutth tom managed
feease’, iewste avis tat sho never heard San Larson use thal erm, an tat Eric DeLong
tothe meeting with Shel officials just one (1)day before the meeting
did not use that term prior
win DEP.
17. dune 28, 2022, Your Affan interviewed aCaseyAnn TalentoofAECOM, Talatowas asked
Lodescribe how shebecameinvolved nieShel Falcon Pips, asked Talento replied hat near he
end ofthe pring process, h centaccount manager for Shel examine he fo provide high
Jovl project assesment. She was alokal the petits ey ha, and police and
cone actos. Tolan esumaled shewasasked 0prior is review n Septemberor
Octomer of2018, several marie pr to consrcton. Talent tated she performed-..a high
lovel review of he peri mai. permis feceed vs. permis olsanding.* Tleto was asked 0
ork wih the Gonsuction Lead and te Projet Manager fo amine complance and inspector,
Inspection
Talento ais hl PocinsGomplance. waswin her scope fork. hewastheProject
Manager fr Envionmentl Shestate thal hsgroupwasna response or HOD.
Talons group suggested and oposed to do bo HDD and pple, but ony gthie te loin
poo ofthe praeet. Thecontador andShelchose 0 un only on (1) spread, Talento
Radassumedth prcoct was 0 bebroken down ithre (3)septal speads. Thismeant hal
Intentof 00 (3 lead, herswas ane (1lad.byTalento explained ha Shell ania 1 have
moe direct cont, owners, and ivoementeamhaving Bruce Barger as th Lead Inspector
To ootinal wilh re (AEGOWenvironmental . The Shell FalconPlancalled ora
Godicatod 1 orHD acs. Tala claimed h El o HDDwerohired drectybyShell
under a separamanagement sucure. Those HDD EIswould be th flld ofwork. personne walking
pth ookingffIR. Talentosa
ong hednl non 1 Gowih I feporing. Tent iswas notwitin hescope Talento
was
amet 0haveth tem ‘managedrelease”was use. Talento responded, askedIierecaed atinga
eating whe es,but | hk he
Phrase used was a cond colecion’” Fret snatIR,itenehconinues, becomesa
Eonollodcallecion pont Talento acknowledged On Jy 20, 2022, vas otin th HDD Manual
Compl by AECOM for the Shel Falcon ple. PA. Talento sate Talento teste before the
“6 Satowtd Investigating GrandJury In PUshrgh, responses. that sh did nt recall
Seng aimed 1 te HDD Plan, nor rainedwilhregard 0 IR Talento tended a
meoing wi he DEP regardingtv Houston #1 HOD, Taliawasasked: Do you ecllwhat
romped you oSay. That acyyou adescibing saconroled release, san indus
andar Taantraped: For me ust seo ke non-ssue, htsusualy someting
nat happenswhen and|ould helpmyself
an IR curs nih.vingkdconveraaion 03dmytwocents IRstat
Talents wes asked: Doyourocall wih Ero DeLong regarding
Continuing hesame spot you recallingEric DeLong ha wasoybecause you knew
Inatl beaconan release? Tent epled: | onbees wehad atconversation before
nat DEP mating Talento advised ht shewa ot na postonof author t maketh final
deerminaton an ncdentwasfoportable a not
25146
1. On September, 2022, Your Affant treed a Todd Janes Wood. Weed avid ht he fa
rion HDD Operator nd Stet Hand. Weed advised hat ho ana fom he nus ole of
HDD 0 HOD Inspections oiaboi 2017. Weed stmate tht he verked on tho ShollFaleon 80
2HODenvironmental inspecor fm Januarof2010 0 8px. Marchof220, when he ook a
lutary ay 0 eth nme. Weed aed hat His ire superior on he Sell Foon
wo Sean Loren, le Laren wes ed om prof, Wood worker 1 Larson
Tepacement, denned a5 Lane reenwall. When asker hero wero obi on the Shell
acon oa ropa wihot a doubt, yo. When asked 0 oxleln what he meant Wesd
tte a. Sean (Lasor) was yin 0 nok coniactors aezeutable fh Condon he
permit. Minsots Lite never worke in Ponyhani. Tney had ys fom Nort and Sat
Dakota, who did whatever they wanted to. No conditions on the ills. It was an adjustment for
nem. Penneyharia as tghtr reuition Weed axpane ha inth begin oft prec
he worked. smaler ils bocaus | Know abt 102d ceasing. Afr Pee wer SOmIS
moved ano ih bigger il When asked abot raining on Pernayania snore 1
equations, Weed sted that ..oeryone was ned i eguiatons on iG The taining
was giv ot HDD Envionata inspectors (19 ae ling rows, and focused on
Penneyiana Department of Enstanmenil Protection (DEP) requiaion. sie of 4 waning
Weed sae“ got out ofcontol. ne bogming, The HOD nepactrs were lows in he
cab, andthe alles were Js onan oun pl fhe oss. You cn waltham
an, and know hats ing on you sou ey are adeng marl and elon, bt you hve ob
ang anton. Sean (Lareo) nodeed ema mters pawsof hl beter ack ny
loss. Elngeon puahed-beck on tat. Tne rough in a meditor be iea ur beeen
Ellingson and Sean. Weed continued: “They had astand-by pay provision. Sean (Larson) was a
tckier, hey waren dong prossaures corey a followin recommendations, Sean said here
ould be io stand pay” Sean Larson was repr
Sean Lason ot red fom he prof, DeLong beganoth 16orin OEP, atoning
vs OEP.0 Weed. Afr
When asked
ner was ver a dvecive tat am I was ot conalaored an thy hod vac tucks mac,
Wood responded: es, hat seunda familar Whenaskedwhy Dong was subiin rors
he DEP ater Larson, eed cise -Becauso Lan (Grochwal)was 0s, and he ha oa
When asked about he flow of HDD reports, ste a he eports wer (0 Sean Larson,
ana subsequently tothe ShllOffce. Weed Weed was asked ete was over a ectve sued fhe
IR: Wesa rep eu. we vere 0d hat woyoucoudcanKoop
oventofan you have a veebuck there, epain.
Gling,ret
2 came longer
om Ev’Garidered
(eons)an
enitonmenial ode? When asked who wou eve ds ha con Weed sited woud
ravewasprobaly comfomrombothhend.
loin ut ffs | ink
Threheysounds e ho alsowhet
rn casito hey isated
+ Weed i coaloo.
seam:05The
Delon gogo woul nt ge uk ot ht Suche. 1d hw supponm fo 3 or a
Teanga, vcked os water meters, ding mu, and adivs. 1 woud chek he apmoved st
tomak sure any advan vues wee approved 3 oo UEP Fr he beghvin fe proc
Soi ho midway pin fo Cortaor ad aa but Fe Trey sare 0 bosons
Compeent at alg abou 5way rough fh projet. | wou sa he ater Plofts pect
ventmuch ptr”
16. On September 29,2022, Your Affant tnieved a Jaco Bernard Reve. ievel worked as an
Enivonmental Inspector (9) on he Shell Falcon om January of 2013 o January 1 2020. vin
ake expan wha is ypc werk day consisted 1, Rive seed tho would alten 2 dob
Safely Anayss
oa LISA) meoting
ou waste mentonha marin.nope!
or depos hic dese
comamen) to wokwichplnfor he day.orReve
he ut
20/4
fetus, inorder to vatohau for a oss of culation (LOGS)andtowal the bore pot ara
Tinimum offouttmes (4%) na en (10) hou shit 0 atch for IR(nacverent Returns)” Riel
add natyouwoud leh he mucman mixing bageof mud 0 ensure hl therswereno
Gnautho zedaddive being used. We had astof approved alivetheywere supposed o
use Rivel natethathe gnerated mulereports curing iswork cay. This included a
bor pat 10. daly report and awaste anes report. Tho dai reports Included the general
Conacior nae, city loge, ptures of he se, and pictures ofthe waste marist Whenand
askedabout HDD Inspecors, ievel aise thaidhemost offenworked wihLaneGreenwat
Todd Weed. He describe theHDDInspectorsshavingmore of backround inHODS:
They wore concerned mete wit ne bore path, checking o Re, and racking th disposal of
Wastes" When asked, Reve aimed he HDD Inspectors werepreseti hecabwih the rl
Tiorator. Riovel statedthatwh he had exprienc itheconstruc flld, e he had 10
speclized environmental experience andlor ain. Fieve advised tha mostof is airing
Consisedofon hsob rang unde hadiecton ofDylan Setzer. Ho adisd tat herewas
“Sembomar vainng conducted on the IR Response lan, hichwascontained in binder in he
work rock. Whan asked, Riel advisedterawas no ang concerning the Deparment of
Envionme ntal i vel ha ob eae queslons, howould direct
Prtecion(DEP)foguialons.
hose questionsto Ez DeLong, {n Lead i. In the event ofan Rot an LOG, Reve rors tat
tingwou stop and theprose woukbevaluated. Typicaly, Reve avid contacta
{oreman. Adelemnatin woud bo made fn rleass made 10he surface orvas
Underground. tn easemado to thesurtace an forwoukd be madeto quay herlessa Reve
Volume Draughvieltheestimation. The response planwas henanaced.Whenaskeda rksoppage. Only
was unable ofall IR or LOC amounts which woudhavereared
vo(3 hs HODlocaton whichRevelworked experienceda IR andlor aLOG, On Houston
7H, love advisedthrewasan IRwhiehewas arkng. Therewerewothe(2)Iaddon! Els
onth se entiod as layne Gat and Lan Greonval. Rieveldescribed as. aside
punchout.Welost lead rtm, and made ntfcaons. Iwas a IR no wetnd,which an
ver some rocks and nt a soya tention pond, along RL 576. Wecleaned otwih vac-
Tucks. The company came out ofApolo PA. NcGucheon asthe company Rievel advised Revel
rat ho was never gv a deci to minimize IR 0 vodwork soppages. When asked,ocause
tat 1h 1 Reportswerenot accurate, Eric DeLong wuld navebeeresale
we submited our ports) 0him” Riel explained that herewas anotherheIincidentalle on Houston#7
10Dtat happend hia Newasoff gt mae, 0 h ound outabout ne
{ack That scaton te oxide oftha plot hl. Thatarea was arasn cup. Trnohy
Wisbans and Todd Weed woud have been th EIshI on se te date and me ofr incident
Wee wou hove been heHDDEl. Hedescbed a5 punch-out releaseoanupland
area Thoy sopped work Revelrecalled a LOGasked, at ris ocaon hil he was resent. Rive!
ated ha OEP was noted of th LOC. When Rievel tate tat onthe hedi personaly
Cesenv animosty bowen the HOD Inspectors and h cig contacor Shel alco. Ho
Sepained: The HOD oye were Knowl ypes. They di ke th way that Elingsonwas
operating Riousaldsated ha ne hove hearsofthetoms IRResponse‘managedrelease”hat andor controled
Teease. Riou tat nliher emwasconned h lan hevas amr
i When asked, Riovlcou ot recall wnat ho pun i roports about he Houston7 IR. Ho
{4 conf thts was he ft IF hich he encountered after approx. tee 3) 0 aur (4)
monthon hob. Revel dd not have any angon how toestmate hevolumeofthe I.
Winen asked how to estimate te volume of an IR, iol souched, heated, and sam not
Iosure. There no eatway 1 get numberan. 1aguess |woud loo tthe HOD Binders
Riovel ado htwashewas roared opul an stmat toh IR volume is report. Rievel
Conied: Tis omeofthefet Gl, 50 taydid have md moter lantvery mar,
27/46
a5vewer her an caught ight away.” ievel level was asked fh aforementioned IF at Houston
1 rouireda work stoppage and DEP shutdown, responded Yes, we sa de ar few
DEP teem ol oe sie Fieve dime do recall anyone asking me to
Gays walingfoandotsepor
iinizso eR vokme:
20.0 October 5, 2022,YourAffant neviasa te Kenneth Books Dads, Davidson began
working on the Shel Floon Project 201, h-par manager for Health Say Security
and Ensronmentl (4558). On the ShellFalcon pec, Davidson dented is immedite
Sipenieo 25 Mery Gersenei, a Shll employee He deacibed hr. a5 a dict ne repor,
hie Doug Sot, Sve ret Manager was adated ep Davidson sai ht hewas
oor skate vests any poring agunlio, om reprtng of ue eprig of Fs
andlor LOCs. Environmental concerns and Inspectors were largely handled by Christopher Haux
ofMimeact Lid. Meaty Gerschlok wou ve Soon te Shell poy respons for
anitormentl overelgh. Davdson Deore ht hr was RomTeporing of der1eporing
ina cored ante prj woud have boondu oa rea down setween Elingon.
Wines Lid, and ie snionmental con. Hewent on ost rat because fre
lime an he amoun; of ding, the, potntil oxld o anything {0 happen. Vihen ask
rere wero any management canoes hath fold personel vere nc sig environmental
Teaatons serous, Davison esponde ‘A ie Minosoa Limited Level, on he pel
Comiructn, he standards were 55 much her han wht {se Guy Were usd and ere
wereli of ences of esos shouto rgastorso put seen rtessonls aig am
rat ings werent 1g. Thy ha never bee rere ork ide su cemanng
Srecomions”
21. On November 1, 2022, YourAfatnenviwe Sashanna (AKA Sasha) Ria Tabaka. Tabska
as maried nc ht ie work on re Shel Falcon, wef oh was eee on document5,
“Seana Slee Tabak wes hired cnabout arth or Ap of 201, shorty afer consnion
veganon he hol Falcon Psine. Tabaka deserved yal work day 4 follows: She would
(JA) meeting n he morning. lowed by walking th bre path fhe
atin
1100. obstay
aTavs wosanaes
sunseuenty check arin contol dices (ECD) look for any oaks on
ine aclpmenton siend xan hse to newt cvryhing was in propor comamen.
Tabet add nt Sho wold alan coracti.itiWhenler te“mcmano
anwoud a ascranse
ns,
ra wers an oso fer 0 ri i Tabak Se at
tei we han Ort fan
okt
amoral mak cotamienhtsoch an IF ndHom
a as coningoncy an LOG. Wh asked 1 Kent wna pe of of
Coningency malts wera ree to be on hn,wrap,Tabak sted a nse ems consisted
Crow been sit fering, sandoogo, tbs, asi and hand coe such as shove, rakes
She ada “Anyiing tht woul be use1 cotawou a IF 6 icka pose. woul 0.8
It farther, with my axprience as cech, lok ath aadives o make sue hy
wove ava pws approvedIndicate litem, ct 1 ld ok ao tr pho 06e
ry ooessed
ners wrTavaka woh wold a oak | knew what ook for, 60
op of,ho gocogy that he Shel Felco faversed 30 bog achalengng Lae
Repti anc an ok a lB of everything? In hr
eat dl. The orca hs ining vod, facies asper ating ofl and tha alot
Coit napoaned hee. Trey ware only wryok(2) eet blow th rac. Boing hat
ion Hoste #1 HDD ark be boo a
Tr. ht bn easeedWe tht uk {nro waUnityGoing be some problems. Iwas alow Gang
Up Wi Tabak sho ann Inspector on oe, who snshared dented ss Paul
Liston. takes mouth shaw depof he pri. vine ase 1 ey any of ter
28/46
concamswit he dre, Tabaka rele: “Thatwould have beenourpace. was ctofour
lane Tabak acs that she was present fo mostofthe Houston #1 HDD, butwas of. or
approx. seven(7) days tofill infor a Utility Inspectoronanothersite. Tabakaadvised that she
Teponed drecty to 4e Dona. She submited dl reports, wich documented whet happened
Ioughout haworkdy. Thywould documentwalkingtnbre path, who may havecamo 0 ho
abate, any Rs, tc. Afr tn Is on Houston#1, Tabaka advised hey developed aweekly
Teportwihpicturdocumentation ofbefore and afer pelos Pictureswereforapartofbot thdaly
anweekly reports. Tebaka aie they ass compiled was manfsts hedisposal ofring
rd and cl cutings. The manfosts wou olcori weighs orvolumes. Tabaka advised
eit tpove mabwu cool nvm Lukor ot. To Faas would
avebooweighedor meuted ath spool acl whi woudhave boon a acy known
2s LWS LLC. located in Steubenville, OH. Reports were submitted to Eric DeLong inan
aeroni fommar Threports would use Word frat, but eywoul b submited na PDF
format When asked,Tagaka stated hoe apo. cou havebeensere o eae ut dor
{ink hat hy were. Tabak sated ht sh nas copes ofof het reports what her sent ema.
Sh sated that 2 a Inepacir sho Know thtnahore wou 5 questions about happened on
Howson #1 and sh Kept iam nh oven shewas ver st dou aie tabi wilh
bores She added Is bar oo slo han sty. Tabaka ase that EricDeLongvas
Getoworkwilh Shestated hat hwas hrsid ge ahold of at mes. Shedescribed him28
Very knowiodgeati shou he aviomantl knowledge of hinge, but was lacking i i understanding
SFHDD, Tabaka foltht she had moreworking on ie evionmertal of HDD than DeLong Shenoted hat
heva sido on hetown ime adeleherellon fal aspectof he indus. Tabaka he
ie ee El ha ad any HDD experience ean. Takaka sue
vironment andDeLong. Shestated
ceived afew hours of aiing on th I esponse panfom Larson
eat she kw ot abou iat subject alaa6 Terewes adn vanng inh aor Snell
cote raining which deal wihtops uch GPR, OSHA 30 AP 1165, ec.Thre was
Salona IR rainingafter Houson1,because tho IR plan was revise and updted. When
eke mal changed afer Houston #1, Tabata ep: Th rs nil IR happened was ke
Cnenundred atons (100 ga. Inthe nal report, was ke thitytreeoaIR thousandgalons (33.000
Go DEPwas99)nonnadtoplases. wont rom. ta nee in coiainment over wo hued
Salons (200 reparied. 6, 1rst IR continued, sotwas continuing I he
and when hefnel numbers
cle tin, een came i. wasway oa igh:whoto Tabaka indsted at
oka have Lane (Groomwal, En (DoLon). or When Paul Laiten) er rat ang
Soucami ion a3 he IR wescomamer, aed, Tabak sited hat sh ner
ear of heton{seomollod ease andlor managed ease. Taba ws asked 0 describe
nat happen on scene. Sherecounted coun sap,
ha th tel was on up, and took phGEaphs. 0 hey
rected ai fone, dug neh (3 hl heground, eae
Sry at rot maser ng IR wih a GAM Soulpe. move She report ht hey hadfolan he IX
wiv Galo (560) Buckets hesause hey pin out dy heavy Squpment af th ROW.
The allowing dayine got heapproval start arl0as8 pressure rom he hoe
They started impinge mug pecause thdlofwas tuck. Theaise majotyof ud hatcame
oecoatmidwhen heywers paling pipe oget done. She a hedosnt
Tamera ho 3 her ws oo hoe Gonbing one he IR was connec.Someoneonsite got
emma om he lndowner, du toth 1 ffhe howey. Wir asked todesc e
eR, Tavs state wasnt on I, was molipl Re Iwas ule a ow. he R esholds wascontained
ood aucun off ROW. ras src.ShoTabokavas unable fo recall
onwoud navemandated ark ppage. hough. th inal pian called ora a1
putin
Sappage fie 7 was over wshundred gators (200 ga. then, you iow, ou 10,
ver: R00 0Eres and Eo submis the rata report.Tha wasai oveme. According
u/4
toTabak, on Houston #, th nal IR was les than one-hundred gallons (100ga), Tren
nothing cam outfor awhi unil ne bi go closerfo hat ation. The second IR was ke sx
gallons (60 gal). She sated: “Sameane though the IR was around Uree-hundred and fy galons
(350.90). wasn cose o thee-hundrd and fity gallons (350 ga. Eri (DeLong) would tellus
nal overreporing was good, and under-eportng wasn. | ws submiing my daly and weekly
teports to Eric during ths time. Once they went o Eri, | assumed that he ws sending them to
he DEP. We even referenced the DEP in ourreports.” Aferconlainment was established on
Houston #1, Tabaka was asked how ne Grin contractor was keeping p with he flow, Tabak
tesponded: "We were using vac-ucks. They would pump the mud back up the hil and pu tin
ine recaimer. Normal, hee wuld only be on (1) vac-ruck pr rl. On tis one we had wo
(2)10 four 4) vao-cks on th exi-ice retums pit. The vac-rucks wid put beck th entry
il. There were que a fw Ro in re fd at onime. twas someting ike hols na am”
Tabaka dd nt recall that the IR plan required work stoppage or a second and subsequent IR
Tabaka added tha there were 10 weekly reports which were required, unless thre wasan issue
Suchasan IR or an LOC. Tre Circulation Reports stated before Sean Larson sare working
wilh the DEP. The focus on LOGSor LORS ait happen unt after Houston #1. Mud meters
Came during tis il, duringashutdown. Tabska recaed havingfo goto he yard and review
1h IR Plan but dc view Ia oficial raining. Tabala offered ha dd not appear that Elingson
Trenchlessknewwhat they were doing o tis project. She went on to explain, Southeast
Directional was experienced; Ellngson was nol. Elingson shited everyone around aot. They
would mov dies from ig o1ig. They had diffrent sizes and brands of igs, ling In diferent
formations; hey woul move equipment and wast (me seting up ig. On Houston #1, the same
lr (Southeast Dicciona) would hav taken 2.4 0° days (0 set-up adil i. Thy (Eingson)
{00K 101 14 days. Trucking was hole. Geting th right amountofequipment wasa problem.
There wer st fence shortages.” As another example, Tabak lec the Houston #7 HOD. She
advise: ‘My husband was ther. Ther wasa ig IR, and hey (Elingso) hired someoneto ona cil.
Ceanup th IR whe the crow sa here and a touch a shovel. That par ofupbeing his own
The superintendent, Kurt Peersan an smart when i comesto cling. He made
ule. Sean Larson) ha im Kicked f te proc, but he's sill wih Elingson. When asked
hose responsi twas fo manor for a LO o LOR, Tabaka advised. that woud have been
ho Foremano the Mud-man. The Usity Inspectorwsthe one who ile ut a the LOC reports
As an El, we woud ge the numbersfo the day. I therewas a LOC, would gt a cai, but tly
{ook areof hat Wren asked anyon on he rect expressed any concams over he amount
oFLOG' on th projec Tabaka ples. -No it piel for he format. I scary because when
Jou ose rene, cou go no creekogroundwater”
22. On November 15,2022, Your Affant interviewed a Mary Garza Gerschalski Gerschelskivas te
SSE Manage or a Shell Falcon Project in Pennsyhania, rom prox.2015 fo ofhe November of
2020, Gorsohlsk dot the Goniacior selection process 5 & maior component pre-
Consiucon phase. She sated thal Shel conracor selection vetting process fay rigorous.
Shel regarded the Falcon Project as ificut due othe tein, Gerschelski noted the processFalcon
{ook months, and Minnesota Limited (MLL was selected 8s the main contractor for theconsucion
Prefect. According 0 Gersehelsd, Mimnesota Lied was responsibe forthe overal
of he pipeine. Minnesota Lied hired sub-contacios for the projec. Gerschefsd sate that
* onytng Minnesota Limited id not have exprtse in, they were permitefo ie Gerschefsksub-
contactor o perform this funcon. Ellingson Trenchless was hired or the HDDs.” The criteria
ded that Shel hadfo approveofthe sub-conlraciors hired by the man contractor.stascs, what
{or veloationof tesuconiraclors consisted ofexamining tei health and safey
was hi background, and fn fm had dono smiar HDDS prior he prec. She expained
30/46
hat th Oi River Dl was a complex cil, hich was designed bo ill fom fer sid of
ihe tr and mock ho mil. Sl wari 0b cra ht hoor vas a ha he
proven capability to complete atechnical, complex drill. When askedif the “stand-by pay”
frovsion ne
noanything Elingson Trenchless
aboutht Whenasdwho conract on wasa concen fo her, Gersanefe
Falcon Pacwoud dameoo
hav hadh | ort
locking nto Eingeen Trancloss oo scone, Gerochlo Safed Sof Adare wad
av loked lo Eingson more hough, dion, Shell hrpay HDD exper
Ido 2 n Ec Schonberg. Gorsohlsl xpilned haGlobal Egwae a party
company ule because Shell eaded a age umber of oy ot ash eroof me
Gerschlsd a ak Sh encounred robles ig expenineed nspecion analfo
postions. Exc DeLongbecame responsile or as9Gning Emonmentl nspecrs to caran
rls. Gerschels red ht ML was noie lowestbidderon the She acon Poe. She
added rt Shellid not see what he HDD company (susonvace) was 54g on he prec
Ra a0 ample, ha 5a hat Shll woud nok ave ow aot estany provi noe
contact Elingeon Trenchless. Gerchelo adviaed tht EvionmentalInapecor had very
Shoot aiing. by anuan of 2015, Snl ad red most of he Ee req fr ha pret
Thee nspciors went0AECOM ofce n
The HDDplan nude te IR Response planGreenies, A fo walk ugh ao he HOD pis.
dealing wih Re and LoGs. Inspectors went
ough ressGomument page by page. Gersohfs id ntatend hse range. Gaeshels
wes asked dosing the Eonar Iapaston Tear on re Shel Felon Pfc
Envronmentl Inspection included bth ean Larsotstarn an Evo DeLong’ oan. Delorg's
peopl
epaenca weewhofetecamefo
to as HOD Enutormentl
anatormetal specs,
mapoco, con, Theandanurcrmenil
iat. pools
rss hapeeps
more
Varacaled HDD Inspectors, bt hy isa promed sional dle. Sh refered om 25
Gol hating” Toa HDD Irpectrs ha ore of background and perience wit HDD
Operations. The HOD Els were ut waking ine bor pth. ooking for pratl Rs, They were
also looking at ECDs, containment, the quality and location(s) of environmental controls, and the
Canin of hese cons. Pat of th 1 ws 0 Grsurs ie atria were on and fo 10spond
{oan pena IR. Tha HOD Inspectors wore th ary persons auharzod fo speak oo arr.
They wouk peak oh dle abot ogres fhe al, apsenaton ne al ca,
Garschlai
Woon ed sed.avast ey nya opors
proachbotharltd ab, ut general
omerwernt iE sonn ned
pecbbe
Seedy énngodi of alr rt being eoponavs oe rooomimeraatns om 1 HED
drill cab, she responded: “No. I've never heard any complaints about this happening.” She also
Inspects. Grscnloh sae a th HOD Conrinlr (San Larsonwas spose 1051

{00a DEP nhplan. Ei boon lo was not orumrats i tv rina pan, a heLead
Sho ado ht wa, or bole ot DeLong wouk ie hol mors lone vw ofproces.
HDD Elwast neorginal plan, Ec soggeiedsl 0 hr curig the erie wht ws
happenin ai he diferent HOD ocaons. Ona Sean Larson wes fepoin fo he DEP i re
Tomof phone nadcatons most fe, and sometime va ol. Aer Sea Lass doris
ams take about th soucoudandnkagreed
recallhatany acaionl
mace sensang or EcoWh hand the epoing
from the project, Eric DeLong assumed the role of reporting to the DEP. Gerschefski and Scott
Teaarements. Gerschalt was provid 10 DeLong

forSib:
i newrable
rl. Shortyafer
wis Howson Ecwas asneo heecaled
#1. Gerace reportinghatresponsi,
og DEP asked threwas a
ot te repr
Raroing
She lated tshaCershele,
hy want backE1 DeLong daa real
an looked ht hahve
ot Plan neededspecies
to SodtehoneTopo
ot0 DEP
togetherwoolly rope and was et. Whenasd ish old boLon to uo heweekly
Torti 1 DEP, an apie: Ho epored 10h oo rfec but was charge of in FR
31/46
ise. Whenhetok over, wetk imtostar oiying the DEP onnewIR and LOC. When
Sokeshot th om managedof coiled lease, Gerschelo aed rt sh rst heard the
{om useby Casey Taio ofAEGOML Shesce rt DEP ws surpriseGerschels by i decision
andverted the opportuni f eview nevay inal an Rs beingmange.
Scknoniedged et a secondo subset IR big would 6a a work soppage and notation to
Dep. Whenasked LOG weroconsdre delon is profs, Gershefi responded
rey a i th HDD Plan. Whenever you hae aLOG,you ae bingver ilgent ooking fora
tanta If one urtacs.- Gersheloscknowedged ht ne IR la ha requiror
Teporing LOGS 1h DEPbt tay out spi volumes ta iggred reporting. She
required reporinofognia
IF. la depenaing
ined ha thndvaried nteses ul rtte fom sricant
aan upon heGl. oe ons was tal os, 1 adtbe
reported.
23. OnDecember1,202, YourAffant nevis Anon Jerome Bours. Bourassa stated hat
hestadon he hl Falcon Pretcnbout Janua 1, 2010as ry HDD Inspocir. Heworked
one Sh Facon unt Feria of 2020, when noKnowled foo avoluary of fom 7 prject0
Ter home to Mimesota. When asked bout his ofthe IRge lan on neSl Falcon,
Sourates deseo plan as a ghar which annoboy undersood Ieoleand got
worse dsto ha evans to pl. nt evtofo take I,we weresupposed 0 5, ake
tren, an watfor a tr.Wowera dred wary (20) poresporde. Th
rer wih fn pln, lo pr sey, waeeatnobodywent ough - Bourassa advised tat
ventof
etoan.
ineoad aWewere wo were suppos
LOG. supposed e I. becausean LOG wl mos ely
1 ean Thi
0 ny Sea Larson, and vatfoapproval0 cone. canis
vane on theocaton ofhl In eritonmentaly snefive area. wewere ore
reas ke a eace, sh as wetland of a waenvay Bourassa dated that Elingaon
Troneios eked axpeince an Kiowledgerereo peron HDDSon he Shel
acon profes. Beason ated hlElingeon Trenchless mpioyees i not apprecile
Caggesho fom he Uy ns Inspectors and i notwelcome hem io te rl ab. Hewent nto
Se ath poctors Suspeced het Elingeon Tranciossvas ding waler LOC or LORS monkor
Beurass nde ht hel concenwas wo Sean Lasan) eduesid meters
espe Bowass role thtin a conta Favorbe Elingaon Tranies, Whenof ask 0expla.
esas Elingson ot Sta herewas a i down. I costa money. Ths wis
nea thcyn actin,
oreent own, Th ute an wa good for Sh, heard several fursof what cost Shell
| herd ost was fythousand cots (590.000) por dy.wes no
Jou have poor dling, hichloo oa shu-Goun, hyataeDelongante inking get pad” There
neat dothprocrahors o Bourassa indeate
ig. Ervronmentl
Inapec on rt nersand ling and ere ergo 8 paycheck an 0 Goof
nen soko abo putes over ne sce ofRs, Botase sate. stmate ofI wer harder
Woote oercoimated.n Eingson vented us to inmze Rs.Manag Thywoul saytings ke:10“On
omaon. Vote ovamaing k- ade: Bourassa sad noone rom em!
averSedTi
ncer-ovimate an 5.|dnt.Boose | was sake bout afin nedocuments a tat Sl
mecing 1iold pom Baurassa Visaod he avrheard fen(s) managed lease
lrcooled No. 11you nave
Bourasss sedsimsyo
ase. Wearanamen a lease, ot controled, on and
Sentara tenons chia Geola ase, 10 lore. Is
Howton #1 uk 1a ot nh IR Pian, anarenwih ats not howyou rl. 11you hve
uh clan hehte and in. | dot ak. If ntithe pan
On December
24. esnres 7,2022, Agents fofnrc a Pil Mateusz Oleskik. On November, 2016, he
2a Ct apc 0s Sel Felson. Theowas supposed ob a wo ses
32/46
wilh% in Pennsylvania and the other% in Ohio and West Virgina. Oleksiak was to be the Chief
Inspector for the Ohio prion, that was unt the contact was signed wih Minnesota Limited (WLL)
and the project became a (1) spread. However, hey stil had two chiefs and two assistant hie.
Oleksik provided he would oversee al the consiruction inspectors, not the environmental
inspectorsor the HDD inspectors. The HDD inspectors fel underthe Chief Inspector, in practice:
they were highly specialized so they reported fo Scolt Adams who was a Shell employee and a
subject matter expert and Eric Schonbergwhowas an outside Shell consultant. The only thing he
had to do with the HDI inspectors, was sign Sean Larson's time sheet. Oleksiak would attend
WILL weekiy meeting, aihough he cdr recall any discussions rat MLL personnel weren' taking
environmental regulations seriously. Similarly, he din recall any discussions with MLL abou re-
raining their employees on environmental regulations. Oleksiak dd confirm thattherewere
conversations about shut downs and how much they were paying for stand-by pay. Oleksiak sad
it was either $25,000 or $40,000 per day. The nial deadline to complete the project was 2015.
Oleksiak advised that he was not involved in anything environmental. He recalled his
administrative assistant being pulled and tod o assist Delong wih puling reports and pictures and
placing it on a document which could be given to the DEP. When the HDD coordinator (Larson)
was let go, it was achaotic period. Larsonwas the primary point of contact. When the Larson
changeover occurred, everybody was scrambing.
25, On December 7, 2022, Agents interviewed a Scott Jay Adams. Adams s the former Project
Engineering Manager forthe Shel Falcon Pipeline, who retired from Shel o/about July 31, 2021
Adams stated that as the Project Engineering Manager orthe Shell Falcon Pipeline, people came
to him with technical questions regarding the design. Adams was concerned because the Falcon
Pipeline route went tough a historic dump and numerous environmentally sersiive areas
\ Adams noted that he did not design the ili profes for the project, but rather reviewed them
afer they had been completed. The driling prfies were done by AECOM. Adams has not
worked any previous pipeline projects in Pennsyvania. He described the geology in Pennsyivania
as significantly diferen, and more challenging. The geology in Pennsylvaniais less
homogeneous, characterized by fraciures, layers, and less cohesive. Adams sated thse factors
make the HDD process mre diffu, ult also make the open trench instalationof pipeline
more dificult as wel. When asked, he staed approx.ter-percent (10%) to twenty-percent (20%)
of the Shell Faicon pipeline was to be HDD. Adams described his knowiedge of HDD as". pretty
good. 1 did alot of themin Texas, Lovisiana, and California. Thiswas myfist time in
Pennsyivania.” He stated that he has. about twenty-five (26) years of experince, off and on. in
HOD." Adams was careful o point ut hat he was it working the Shell Falcon Project fiom the
beginning. Most ofthe designofthe pipeline had been completed prior (0Adams becoming
involved in the project. He reviewed the existing plans as part of the onboarding process. There
was a limited amountof design which took place after Adams joined the project. AECOM did the
design, the designs were sentto a HDD Consultant, then submited to Adams. Adams tated that
the HDD Consultant hada ten (10) year relationship vith Shell and was hired to provide
...another level of review outsideof Shell” Adamsoined the Falcon Project on/about 2017, and
he was there throughout construction. AL this time, he was based in Houston, TX. When asked
whee he was during the consinucion phase, Adams replied: For the most pat, | had a bird's eye
view from Texas. | took psfo the sie two (2) mes per month, butas a ule, | was in meetings
with the Shall Pipeline Projects Team.” In addition, there were cal-in meetings wih hs
counterpart at Minnesota Limited, dentfied as a Mylan Koski, every two (2) o three (3) cays.
When on sie in Pennsylvania, meetings tock place at the consirucion airs on the project office
site. Adams indicated that Shel desire to have project leaders have an on-site presence.
‘Adams was unable to recall any problems which required him f travel to Pennsylvania. Adams
33/4
ass
ee sto en contactorection pcos, Adams songs
Eoesas to ates vos aLik
sone(LL)
oan am soosaosiSas Sven ato mrcoats wore,
APAN on. SoswnaSor varsspas tog
eaoa i orem: iarams
na She droog Hpmeroota
forEllingson Trenchless. Adams replied, “No,notthat | can recall. It was discussed, and it wasn't
ee at aotoaam pt
ee een rae es, Imag ve waaay ikaveg oe oto or Mesa
borg rhe eset,ohms
vag oppo andong.To
ly3. iweg hr 38s sop 5
ome eo ea.
ato on mea Hooatts
fe sorts hnsotto waGoioe50
that was incorrect, they wouldn't get paid.” If there were any HDD issues with a technical piece,
ee rrwes er 2106:
eb oasessoi sopr ar mates er wheeet
ap home na,
Stoy Tarrls eet peo
no, ha easatom
erewas copay ie wowo ovred oso. 6
tn
gros amen taeh ea sheetin pf Whth RPrs ws edo Fa Sse os Pr.
oe asSoh re cn on. tomsslow Snlowed op
he reviewed the IR Plan. He recalled having at least one (1) meeting with the DEP. On/about
Fr aa ot what eso mart ian

ensho alg heat rai
redt 53 den
copaies. Pepin
gid do
von sage
eodo waaxs me orAas
se1, bi
honesaa comesete eaves anTae tenveropong
8 repair messes
vosmasormom
ae ae poosetanot
scar ectod wn
asen. rtets in ocr D2
aor ospoteo
eeaesabsotostascot cmon sovagean' ammonia
He ergs om mess Semanaws sosseen
pone pooped
ot. asdiecamspots
otEY.
Be ages gastos ones wot aesorev aes pete
spon Gd
Tons ontsm Sones ams savorwos oe ov banapis std
pions a ae tae ov ope
Decambar7, 202,
26. eros Agora ties Sv t
Faoi Dugas
pain Sot
sh (AKA
Engen Dg St).
erage Sea
Tom
er iy
itnSevemc enht vaor conto argesae goao.
Pgot oo Pech angeron
ee
ee caleen uyofaregos ecta sioes 0 palo sparen
‘execute the project and to meet the goals. Health and safety, quality, environmental, and cost
A oo db EA
goals. Scott was asked where he was running the Shell Falcon Project from. Scott replied that it
3414
car to Pennsyai a iceper mon. Hendadded toneconsucio bgan howa, bas
Fame ot 8kre r (3month hn slow pled890k 0amou nt he was
ofUm
Pe. Seah denies StAso, th Load Engineer, ash anal Sbjct mr
te ma re So wes none extol conta. r Saheb an
eo ances einen. Shenton hod AEC of soa PAs re
OM
romoann sonra,a Speco n oh roc. Set
ey od DDbogscrato ovin ewor. doth
amon amges pennmyva ia 240s Sot ate ht
Shot omewimestaiments Lie atersensis orc mt cttpan ad ion 1 ds
ver snes Lid hepret dren nee vt i, ATER
mace ammorscost fev, Once Minmesta Limt wassate,ed toy requeld Ellngeon
Trance a.suona for OD. Set adindicated is wes du 03 13 ml HDD which rented
wastythwoywoRIg mich 8 OEPoEf
that he had no serious concerns about
esa oy, rovers wine cotaand
‘an intersecting drill beneath the Ohio River. Scott
r stdnlotdh
rk Sop p
coegordoy. Senca ek wes ly
som he mea a a rporei fo ohcoreini on manage. The
ove managesrennin epson he rfc provides suppor and Comptes SSE reports.
moots Limes . ToaneWoneaota plot whi Shll roel heavstan ce
andig
ero poms poran toSlcovac Limiod conshaeionmanag er nmin Weshow on
Er arom and he wt 8 LOG ran 1 hoyionarege r Ten rewer oesmean wih an
ates,
Set aad I Lote, lings. and Seen
nas rea (a ov0n i, a oy
oars tom voswatesrave
P08o3ls130oe nspacir(9bdto 1smomios on ht
en all
mon, ato gr on a inthe
a open. iho 1st. ty sto ar wl 8 lo Seo mated
tga tring mon a LOC oth volo,50wheterwork wos sapped nd f DEP a
oem ogg okbigpresent tv HOD 5. DEPvariefo kro aure
sta Sot dos te maeingwi DEP at ve ovin he
enki daa onefom Sal coktn snow. S63 eons,r quent ul wre oS
ment wat wlalow res tr
onethprope ad been
ret onhapang,wi Dh ovibyaoofpplowed. Scot dare, Ev Sehonbarg, ant dota
ri Tot errsshomes he he rn Seok) nt a0 tooclream
am HD rs wateredmet as. Set hghmoter
woreSanus oth wite155
ooovine otBingo ant. Trnilossred hwardleanearhe nd
dd not hav cond HOD
a ctopmkuinwhat th term of
ree Seo ead a re ans araminr etapa 1Pon avd os roverrend’
27 On Dacember 8,202, YurAfanteniew ed Superior fom heWaray
DEP and
a roa are SRG rgaraingfoc. notaries Shel sui tretedof10on and
Ce Bacon pein consesaton OUP indeated hat ShlShlls documeniat
ed es 3oka mdet rtwrs s nt apogallonowien loonof
DEP aesured pit
5 BAT00. Ths
re ht (ALG of8.105yo. Doon vi vlcamalt Hoon 3) A nse apiatnof appr.
essa wa ben mad
occured Hous #00 08152020. henac vas 1a
Tans rs sea ah n 5 Ahove poet. of appro. 50galonson
re acon. oy en bea vavam
etaton hod I adn soon md Se Laren. 71 Inv
Eas Ts wat a pono submi por was eresE16 DLO)
on. LariosTraare woot Tepes anseqenty
ane DER etese Shh fated
en to reporin equim. Ts 2800 was Sui up wilh Shlladsub
eos
35/44
28. Orfabout January 18, 2023, DEP pointed out additional incidents thal Shell failed to report to the
‘agency, in violation of the permit. These incidents included: a 21,000 gallon LOC on the Houston
#7 HDD was unreported. A19,116gallon LOC on the Houston# HDD was under-reported to the
DEP as 4,909 gallons. A 2,800 gallon IRon the Houston #8 HOD was not reported intaly, but
contained within a subsequent weekly report submital.
29. On January 20, 2023, Your Affiant interviewed a Paul William Leisteen. Leisteen worked for
Michel's Corporation from approx. 07/2012 to 01/2019, Leisteen worked in the Horizontal
Directional Driling (HDD) Crossings section of the company. Leisteen started in a general
Iaborer's positon, and eventually worked his way up to a foreman's position on a drling rg. He
left his employment and Michel's and started on the Falcon Project on 01/2012019 in Pittsburgh,
PA. Leisteen was oneofthe orginal ix (6) hires forthe HDD Inspector team headed by Sean
Larson. He described his training for this positon as *..a series of e-documents, videos,
presentations, and on-boarding materials. We discussed the IR and HOD Plans in depth ike how
to respond to IRs and environmental inspections.” There was nothing specific ths traning
regarding Pennsylvania regulations. Larson quizzed the HOD Inspectors on what to do in the
event of an IR, such as call a supervisor, estimate the volume, and follow writen procedures.
When asked about is professional opinionofElingson Trenchless, Leisteen indicated that
Elingson handled things differently than other companies but that they were not incompetent nor
were they trying to get away vith anything. Leisteen was asked to recall if there were any
problems on Houston #7. Leisteen replied that there was an IR near a sound wall off the ight.of-
‘way (ROW) at the start of the ill. There were also approx. two (2) LOC. They tried a couple of
things to restore the flow. There were also some issues with getting the dri intersected from both
sides. “They struggled with this, but eventually got it done. When asked, Leisteen remembered
that Ellingson ost some teeth from the dri bit on th dil, but was unable to recall any of the
specific detail. Leisteen was asked f there were any problems on the Houston #1 HOD.
Leisteen stated that he worked that location with a Sasha Steele as the Environmental Inspector,
and there were *. os of IRs there." He claimed there were no issues unti they lost al returns
and the mud popped up on the opposite side in a farm field near the exit side. According to
Leisteen, most of the problems on Houston #1 came up after Sean Larson had been fired. Lane
Greenwal subsequently assumed Larson's positon as the HDD Coordinator. Leisteen was asked
if anyofthe IRs would have been over the work stoppage thresholds as defined by the IR Plan
andthe DEP. Leisteen responded: “Any mud that came to the surface should have been reported
tothe DEP.” Leisteen advised that he would only reportfo Lane Greenwalt in his chain of
command. Leisteen statedthathis reporting responsibilities ended with reporting the IRsto his
immediate supervisor (Lane Greenwall) and documenting same in his report. Leisteen was asked
fhe ever heard the term(s) managed and/or controled release. Leisteen replied that he didn't
hear that term used on Houston #1, but that this concept is nothing new and he had heard it
before. The concept is that you contain the IR, collect to prevent the IR from spreading, pump it
back to the driing ig, re-circulate i, and continue drilling. Leisteen stated: I didn't hear that term
being used on Houston #1 specifically. It wasn't ever said that itwas a recurring IRand they were
going to run with it. That terminology wasn't used. No.” Leisteen described the mudas*...coming
out into an alfalfa field about three-nundred feet (300) from the exit point. Laborers with shovels.
and squeegees attempted to contain the IR. They put plastic sheeting under hay bales. They
would collect the mud with a vacuum truck, take it back {0 the mud pit and re-circulate the mud.
Leistoen advised that when they got the re-start etter from DEP, Lane Greenwalt said: Tell
Ellingson we're good 10 go." Leisteen recalled It didn't make any sense to methatwehad
‘another two hundred and fifty gallons (250 gals) of mud come up. We measure i, it was reported,
‘and the mud keeps coming out. | asked specificallyifwe could have more mud come up and i
ala
wasokay. Lane sad have fhe a reso,
yes. | asked him (Lane)(1006000 and we GI rer,nik andthenonce
atwas
repent fs okay0 Lon ak, Lan33d in Gane gl) 0 com up? 1
ooo vatswhat 2 ong ascoi unth samesc, hen
vas oy. ook a eteoftheDEPeter and he repr. Lane ana Er(DeLong) were taking 1
ine DEP, 401 jusxtumed he wsawareof. Loincontinue “Thre wre uo (2)
mor report ofIsanthtones s and h Glance between ference. We ot 0 ephry1s25.2
th wo 2) af hr was (G0) 10
forty fot (40) wh fer, and erispracial n
Secondones Lane. wentiomy supeniec, who was Lane, ana auestoned hi ice. Lane
S20 as 1 fo keep Gog and a ho DEP was acs aware of1 When ase, Loitoen ses
was no present on at lcation. Lfioe
ratFldDEPGiuiaton tet 1 ruber contained n the
port wer accurately epared oyhim. He repre th nurs provided 0
him by Sasha Steele. Weekly Reports/Summaries were compiled by Sasha Steele. Leisteen
cod: re flo heShh Felco ater in ac. | rk there's some cansion aver the
mbes. Tham, Ri, read ht ws Ko orn thousand galons (49000ga). That
oye wo hun (00), es huned (G00), or ourruncred
Soundsgallons
{400) on herwasound
muhere
Tk aioof ms a any ono ime. It wisall washed down. It cna alt
oree ma has meaty. oo youto Laiseen, go ack at Spt onthe when found novGreanualsuit ook reenovr
poten farmers fa Aceon non changed Lane
Se he HDD Coordinator. He desotbed reenvalas educated n HDD and sophie. ot ter
Cetoen sated n wes myapinin, Eingson was hot aap leh HDD company. vas why dont
ofincompetony, more ie norprence |woud sometimesao nereman,
Jou ajo. Theyob na hy 0 6o anyting. was ke wn fey vereut
piondnseem
oat andThey ha trcapment jo 0s . and over bis. Theywou
Yowana
orking, he noughtwaswhatwe ge done, we gt done,” Liste stated atonhtHouston#1
acamettom het Lan (Greomvaty and 0 (Delon) lowed everyting re DEP old
ram 16 hk anyone 0 me 0 corp, I, wild formato. Wewou scpand
Teper he mu on ne Ground. Loto was aked why Sean Larson wanted onal valor
neers oh igh Lian eple Thoy wera ried or he HDD Plan. We sou rave hod
am:
On dannyranhiees
30. Clngeon 25, 2024,viaYourAffant a Jeremy Elings
nenewed on, r ofof
he Chief OperaonsOffice
8 WebEx alconferencing appicaon Fout (4)Pala addons emioyes
Eingeon Trenci were soonossns callTroy ar a folows:
(DO Alco
01201668). (008
Opersians
GTaE00) Operations Supernancent, Gur Petroon
Supettendent Raber Hots (D0 01161688). Profect Manager, and a Micha Schiursky
{568 12151670), Projet Hanger.deElingson provided examplesnate work ht ne company
of priorhtseenty percent
fue
ho peromes both winbeamand Porat. of enneania Theyhrwero ohalenge sHDD sin
rans of awork has When asked
Panreyhan, eremy ple Yes. Th aicomes seep,you have
o mind. Is rocky, you ave changes cevaton
Coamges, an Ts tough vo doe wihGooop Tins. cu. Th sll condions aesmi. fou hve tht
eval. and you pve abandonedtahnges shu Thegeology fs otborer Efngso aavsed
Toomey in osformation. a nolo
t Jeremy
verydt Panneganiao halonGinG. Hing 8yoo to manage Rs important.
Sits ht he ys andfobhahy process SUTPennant ha wassepTherewas Fan
on neSlot of sensivy vas wood
around
nt eter anany othe pact.hodWhen don in d on
Eionmental sve and si hat Elngsomwas asked abot he Hear anor chainofcoman Lied.
ne Sn Paleo Pret maracod Jeremy asubconr or Minnesota
actr he profect
Einpson atorinanty on wih Wonesota Limite. Jaron sled rt
ovobe 3 semamos ros) ananmentlepociors onts HOD tes very oy
37/4
rem at 1 sat of to rfc. They poco 2uh der an oe mrs and werent
roms or sen of ston (L004) Hinson spares “Wo cou osu 0s usar
pean ote Towo 2) apeswou
werwen. aadhon.Worew ots She, ans
Eels nts meso trae as rors Gomoany KRW88
ere oe. ntfato toMiso rs ime was cl ase vi one. Ther
brought inspection people into stay with the drill rig so there would bea rapid responseto fluid
Eawat tearsogim ut oo apo hgeoe vesha, ooktme to fom
get36epones heDEP.
Tree est as Lima nd Io swimmer Paper
Eons s56e8sre tha ere wir tes wheomSv eywere shudou or ine (10 1 wie (12 ays
ers wosan oot sf cran e o hrs Miosots Line.ody pa, asked1fEingson
oe ova Baga eae. asSom t we dt gt
re ans Aros eka sane by 6p.Bingo bt rn teaire avertosta hywre a
ato tesior vay 268 pan a6 ot hows ancor kingbac taing 1Gt.
elcompane svar so hyvereoe Foleo onsan.of ntwil ow me t
otrmedil
DEB nt ow
en reat foJr imc mover nt of isborerHo oan at ey Pc
atts 150 pa
mera, Bingen st vr 3s someting 3 on wit DEP,1
mon #11 ie Scipgshy ses tn HODhatPwo vowedoth Eling
ques
Ce oreepo sma srtofsoc ask HOD. Sings whetpro confined IRhoHouston ohh LOD ako
totaling, Ehngsenwas 10 ech plat £2 mudsping
pefoam ton 2.000 a resto cons. Thy caled iare.ot. Thywets 0
en Ces to gallon
nd 50003) erdy
Iethousa ake abeaion 6 how deep so G1, now rash, hywer 0p work
eesSa
Ee se os ponwok veywaks oomar ry Wk wo evra POT 10
eaareponis ay eytoahncs oar f-toowsPonants. Tha ppg wo ough red sate,
mui10Poly
her ste, Wha hywae
ey Singer's pcos wes ney the gonerrcrra cr Minnesta IIo) 10mater
os lr was heir h aperlrref ed ho OEPcomet Consuing
wat up hr.SlAleFalonon
oeocumeme saay lingson+0 hobogan work I n on he March
To sonform
00.207.horof do dowas Gosrbed
ao. oot
wna ho #11 an wiepost
sktoh hy ovr vr ht rd manage
odor
an
apann
a tered wood
ron mt ante tor of iol b eltwo, bu wasnt
oie Ropers Hs
2614
retwel.
Sram Tacoma The superintendentforHuston
a eGo s 1 vas Evformer
esa empeye
wis whovasnh
ror no orga
ot ih
Ervine nape Betonvaks howe os respoiy otmig afbe rttcaions
DES. nite fan. andoun artyweswih a. 5 onions
cling hom Slwould
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oars a rape sing
schhs ss spor
HD would When
eve ne plend
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meocs ea mais goo 30 gaesol fora nde,
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Cormeen sms Secs (ely,
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$1. On Fry, 22%,YourAtn voveta ClkGog, Gog aden othha
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elas Ws. 1s arena
Giluve. opr
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using Google
ron pein, Cognos ie wins hit hehe8 sve mony so 10 heGol, Bue
Ee oi
vost oniran soo ote dogs
aartvonSoe op.feetSwabs etapa. adound
that the
oane
original drilling surveys
ts
were
so
off
he
by
srs poy ci:
twenty-three (23)
When
tothe
ud eeho
northwest. Our
meaan a venve Ee hamptontoo

anova Toesere he er pineonPePaO a Plo. ovens
34/46
tan Poe Aopen ion pl roc
To fot,volt a
d esing
a pomped wih
To mums oor ye of HogardFor
00) gt rd £015.
i:artwoo
oa anon 8)popmero usorFo ts rc (15) rr ses oh
yom, ayer ossore eeihoe arma: Whenops
Cosi sta
ee
vers as
owt Hoso
wih pas. Trey pve sv ag. Mrs
east ot (soeso ni Vir wold
DEP rns mod
ate oo hago hori
me hens vt aonb cong. inns Led Evian
“There was a guy from DEP, his name was Mark. He had a heavy moustache. Shell
i espace 2 1 hv eo dompet soma er

rh reo. 0.
eaermast:
nee geeneota
acs. s, ve modemsfe
ogame wanes an wowld
Tee
I ant Ce 0p Elgeonws noesi teoc. Trtwe po Sh
coat, omty ated stornies
fo Event. 3530 9)no veod
tenants rb ont. Diy snd
reapersso Soca hd oe nerd an son (127
rarer ons?
Ee ete Sinbory nae nsoun HOD Cor fs on
BeErte3001 Shorrwesstew rtca oa avd 10
Fmas a sarepot on tne rh acon
hosor Paine.o AECOU
os of
neomineors
x cho a oyweld
mn tS
so ero oho ras0
BD ba waineer
soreconmeason mparan cosore
wt100. Son row As a
arts Soren
Ee evekon in res con 07swh he wtrdora"
toy
i cov
sccm oot.0 0y otevohSI
component Srl Foefn
was mane
sto sop amocha
ovr es1m maven: omeha morayaon I
attr. arin veh
Toe oso
(ny ma’ iveasd ooteos) rons
somal ho oni.
Eo on pie, hem
SE sop oh espwih vinches.Dlg nr bra
an as
vamos nessun: esse Sommpu samoteots, Three
apr wien
ses sks wr
dor boIv io
oe pechon
soe name an
no en oo soo wim
ean re arm woo eewoop wor reo seh mgr me
40/4
gues aowho! repre 1 on is rjc, ut conan woulo andmeet wih avers Sot
ey vda 3 r concamieh woul bo 0 ii am 100 frSPO:
Cementfiveny oe oasis, vo hewadhadcome 0 Pomona ono
or am: Somber scoen ay opr fo th soto The repos Goes
to
‘month for three (3) (5) daysat atime. In addition, weekly meetingswiththewhole
ain somstar: ownhs ard ni pln. how mn ey9 pug,HDD help a1

rasanof smi wat,ent of ali progres. A to Cora.
es piety mere rested waco of ve os. rd i dG
Conran aking at Skane mca hathe ented ns mot ociclGhllrdng
Gi toasty complet oofnop bre (3ov(5 HOD Conti. Sel
Careraos os gpeaions andwentwih Slaton rons. Skenbrs sarod nt beno
never heardof Elingsonpriorto Shell's selection but that he found them tobe a good, reputable
Serer spores
onesSnake Skambesg sted
Petwa vooewithDD
very gn, mole coving Psion.
oorinors ain Soverl rfing os i
vere opersing smukansosay Cron amour of avy,vos Sorbers speed ad a DD
Ceonanator wn varaantallow softh HDD apart ntdalydle. Th woud o poke
tom poring and foranyihing suport nr repr. Shelasadwih
Seomaar” mary soseuerny ou Seam Lasts 1th toShel Larson's apecemert
are mamma. Hesomata ht Lane oppo fg nd D4oso,and ver Hood
en Sonnysitet dt sive penir Repo Report, addonto
ting dat and Repo esd ofmut lin. Skonergotsated ot he nt pct Erte5 Dy so
Sve
i iat oso whiteor rth (oFCy. Snort hepato wiles
wsapra ov ft.Sonbory
rem nh. herswore 12 on th prj According lo hone, Soll would all i0
ak are any oe we noudong? dog 110d th: Wo or oll oa,
omaha, araopervam. ht nywer evothg hy sho oodong. Based
oon namoof HOD Ag ros on ne pret 806m erswire or ot ars
noe ar wiemar amin oe. 1Toreverswary 20) rossi,so hrs
eer veemoshtts ier ake whatrouge papened eveofthof 3profo LOG, Sonnet LOG ele
we vosown ttoro he langh rele.Wihena was
orale Pump, top ain, nd 00erway. Wowoul Taka Wowold oly
an onan dant vot pon sagng we Snot ok 1cron, Shll wuld have a
meet Porto hatims lingo
suggeaions.Supentndan, Guo HOD ave wearer
ropes,
oswoldleysobsonsnty
pe Elingson ans fair go ouine deal he
tort spine roving eyct an questo ihheplo. oa the Sobers
ee pesca Wor 0tvsExactsass rapacersona woud air onth fot
tt ates ert. m aan ba evened of620h 38 0
em!
ee so orewer os.
Teneos ard werd oho She Foloon pple Pre
33. On February 15, 2024,YourAffiant interviewed a Dalton (AKA Dino) Darden. Darden was
bats nosyaBingo
Faery rem vo encores an he Sho Foleo. Darden respond Fs
amt at wart very sh lingam suid210. Terewor Faov, Wh yo |
hoycou gt hl 19s lohm.
at arm. avs sn ow oki est yi ca. Elgon a RUDvty
ou osmom anir dayconan amasSings che ol, leaders, and lr il
arr foe.
is mative mca What | meal thdl cuinge erent
ha
Ton et von. Toa sins oso a20 yo dot i ut helo wih cing, OPce
41/46
got thre, sighton them up, 1rd dine Whasok tomoetof 1231201" According fo Date,es
ota msple wos ees wi Elgonol Hom aneabot herovlr of anh
in ston rac us wore peu profes, iew oul oly DEP.
Thoywerd qu abot wesigaions
Ee eta
eo iwl otiam arkdm
sse autatl hyLOC.Ivestgato.
are $3. Wowowih hd LOC.ihre.
n
Severpretymas, he ob
farr
a fot ran Yat ere bolowhe
von 66 hd sh Sou or shou iy (30dey. We ha lie HDDS
ee. onWhooaud wowould move0 ahotht Jobste” Drdenwasasked
Sing a ance doy os painwatow, he. He responded When gt ore.| Sar standing
a Wo Ho oo fodor0Ga,
aLAM. Ove secon of pe was ple oy do bor 01 t anolmats
Somosings wi crow woud bo gong.
eno radeup pn ros because the ips want pedovrall reno | met HLL
re emia egot ore, mein Ses Lorson andwont he il te. Thre
re sea Wot slore eviner. Toe (Elingeon Js sri lin. Daten advised
aero sommimeson He sted cut tet as
ea lgsong wih rt
rene ed Sean arson roy aarphthonetn co to ang. vou kd hk ofim3
Commotion wives a a2 ooh anHoheSeon, gor Sackae nh lotThys
ma Toaodes nL dl andhyvariedanySans po. yuwarkmy
nn, ramwest Tat at lHwas 0on Oe ht ha abot lingon
ini, ean wast ntwes Lan Grea He desred
tea Dadan ses tanutLarson'sreploceme
osmetrothn Lots Dard an ot grt ComGr, When
eameseniedgeai man reining on hs poet ogfo Yo, Derowe 6
Sone
ein, Torwie patedfacet and somebodyvaried ot medion andescoanuo
Foi. Tom wanied messes of. Thatswhen heywar to al To mers
ane ov had oe. roomona or. care Up wi were ready to pull pipe.” Whenpp
a They wore pl ack
ores er
sheets. Everybody
s lngaon rnae
tsrceswhere
to sign-off the sheets toensurewe
wasbetantss reprIR nd LOGS,
oven aovsoarat heeywars t mes estat vaca eyvere 501 anid she.
ee vata on Howson 1, Darden sa:vos | in ts Ci ogous (ah
mandir,saaotoeha ons ve beamrin. alos a contled In anlose, thyCotes
ovrherd
om an Toa od tore. nov vd seen ae rls ae a areged or creled Dien
arson venonecomecy MLL lttkeep ai or wewor ri. 1d ofhve andGea , lo
on sat ei soa ing. Troy wart ak pre Love recat and Ex Dolo oul
eeesas toreard 0oi
aevsswtrespon
partetoes dinggswoul hve camaTs
0h DEP. Ev
ee rv wore oi Sh Fan rem uy of 201 10 apo. anaes epor rc and LOGS of202.
Deca
Report compe
Operon Gouament by Elingaen Trenchless te Shell
Your Aftant
34. Fo asllyToco repos
iaeviews ne tyOperas
ary aeetonl con nt coton70
Reports dosime ters
htwer ot
TOeo s3y Sesof dos. Ths nla dons neu:
es bap maisof a erento
ADaly Operations RareN
a maou. erdy, 22, 201 rn
Ap cated Hovson 7HODlocated
lonLOC
hen Coun sie herewas 21000
-sigitcan LOG: asepatdald hthoter
a hi SomaL3G iwots 1 sont
sraeoones LOG wan DEP and
resid ma50 geo i ufc waters of Gorman
42/46
bo. ADs Operations Reported cosy, Ap 24, 201for Houston
te 820D
vaso
oes en sn Towra shin
dl pp. Geant
Eve. hn To croit vs ope
re mtofseo, 50glen
So aPR ae it Ti 2% was ep t
ee Comrie oan ave reware 3os icot. £0
saan ston Tocr oo Fo
Te a maaa wo sero n
DalyOperetons ReportdtdT y,An25, 201 ch Holo #2HOD which
a oe aemeant coeosorsah dove. owen
Sv JotAror ov evned
som haon OD Daly
ea ov rosa og eso apo BES. Chai ws
ea ere sarep s
50gam ro OEP.amc
naman uted oh
stn
BE a Svs son. oe on hes424301 1 eam. an ho
oe oy omar 8 pac and war 688
BANA nt
4. ADs OptionsRep orted Turd,May 5 201
ect. for Howton#2
I ascoro
52%Selo 0D tishe
a ies vs, yes
scoressmoot5 gli. To 1518s ted
asto
tne on n ain ho re oiNero ow 3) wre
. ADs Opsaons Repot,ded Tossa, Jyty, 2010fon
cand osina #10HOD
sevos Sgn R31
np ey vd tig id oro,
esmee ose et seb i anw THe et el epontto e DEP.
alyOpensetmeve Ror, ee Satur, Star 25, 2019far Hosstn
on #11 HOD
nwesingon Gout
Fp dated
es 100
Saprobe 02019
aaae ane a. Ao
isoions. Xo Coan
parton rootaeds ober 2270
v0ton. A boorton eon apo edcor
colo Geer 71.2010
3 3010
sodas. A oyoto
Te samnoned
a 00 lon.oramont wat epee
Fsntep ae I Bt 10 0 0 EP.
ee aon
oe wes comin 373.
oats dou oidof ndeThe
Eent 0 wascompote aot Nova 7.307.
ed erasor hoon To de potrewer
13604 ston. io
Thasgeel
iere me an
Sem 40028 gloan
te brswold ve ese
asha os Celong sams
e8.376. es
oc ors
Oona oe
nd
es soensanmcs
eos es owashors
nin Sepaso on eh ndgoon
——
a Daly Opera tors
Report,ot ondey, Far
Coon 2070
meses ry,
10:Houston
amon HOD
OG
a poe
43/46
losses occuring throughout the day. A LOC of only 4,908 gallons was underreported to
the DEP.
h. A Daly Operations Report dated Tnursday, May 13, 2020, indicated there was an IR in
the amountof2, 800 gallons at appro. 1600s. The IRwas nol reported to the DEP.
immediately. The IR was reported in a subsequent weeky report.
i A Daly Operations Report, dated Tuesday, February 25, 2020 fr the Housion #3 HDD
located in Robinson Township, Washington County, indicated a 200 gallon IR st approx.
1355hs this date. The IRwas not reported to the DEP.
J. A Daily Operations Report, dated August 4, 2020, indicated that 6,184 gallon LOC
occurred at approx.125hrs this date. The LOG was not reported o the DEP.
35. 1 addilon {02reviewofthe Daily Operations Reports for environmental incidents that were not
reported to DEP,a review was undertaken to determine whether of not any of the inadvertent
fetus that occurred during construction had an impact on Waters of the Commonwealth. Several
ofthese impacts were discovered:
On Apri 22,2019 there was a 300 gallon IR at the Houston #7 HOD in Finlay Township,
Wasringion County. The IR caused polluion 0water of the Commonwealth. Diiling
fluids were discharged info wo (2) UNTS fo Potato Garden Run (S-PA-160405-JLK-001
and S-PA-T61205:WRA-001) and nto @ wetland (W-PA-160405-JLK-001).
b. On May 29, 2019 there was a 1, 500 gallon IR at the Houston #7 HDD in Findlay
Township, Washington County. The IR caused pollution to water ofthe Commonweal
Dring lids were ischarged infotwo (2) UNTS fo Potato Garden Run (S-PA-160405-
JLK001 and S-PA-181205-WRA-001) and inoa wetland (W-PA-160405-JLK-001).
©. On July 22,2018, there was a 500 gallon IR at theHouston #9 HDD in Independence
Township, Beaver County. The IR caused pollton to watersof the Commonwealth.
Dring fluids were dacharged ino Raccoon Creek (S-PA-15103-MRK-002) and a
wetland (W-PA-151013-MRK-003).
4. On September 20, 2019, there was an 800 gallon IRathe Houston #11 HDD in Raccoon
Tounship, Beaver County. The IR caused pollution to watersofthe Commonweal.
Dring lids were cischarged into @ wetland (W-PA-151123-JKL-001).
36. From April 2019 to onlabout Novemberof 2019, Shel fad to ensure that Elingson Trenchiess
HDD igs were equipped wilh real time, data logging instrumentation to record the folowing
information: borehole annular pressure during pit bore operation, dling lid discharge rae, the
spatial positonofthe iiling bit reamer bit, and the dri tring axial and torsional loads. These
data loggers were a conditionofthe DEP permit as defined in the HDD IR Pian.
37. Your Affant contacted the DEP SWRO located in Pittsburgh, PA and received acerication of
records thet states no record was found to exist which indicates that Shel Pipeline Company LP or
Shel Pipeline GP, LLC, or any ofher person, company or business, has ever applied for, or
4440
{eceied, a permit pursuantfo the lean Sireams Law, 35 PS, § 610.6911 t seq,todischarge
any wast fom any sour, xceptwater discharged from hyirosa testing, ot or nar the She
Facon Pipeline Prefect ocaed n Alegheny, Beaver and Washingon Counts, Penneyani, or
to discharge any waste from that project site(s) into any waters of the Commonwealth.
38. The Clean Streams Law, 35 P.S. § 691.101 provides the following definitions:
qi, gaseous, rdocive, old o

2. “Industria waste" shall bo construed o meananyanymanufacturingo
aver substance, na sewage, esting fom indus, of fom any
Seautahment as bran define, and mine drainage, ese, Sh, coal ine sok, foc,
Geb, it and lay fom cea mines col callers, beakers or ctr col processing
operations. Industil waster shall incude all such substances wheter or not general
characte as waste
b. “Person shall be conte 0 include any natural prson, partnership, association or
corporation ot any agency, ekumertally or eniy of Federal o Sate Government.
Wihenovor sed any clause prescising and posing penal, or mposings ne cr
imprisonment of oth. 16 erm ‘person shall not excude ie members ofan ssocistion
ant th directors, aficers oages ofa corporation of the Commorvaltn
“Poluton" shall ba conse 1 mean confaminalion of any vaters ch waters hari,
such 8 il reat of klfo crete a nuisance o 0 render
deaonta of rious 1 publ heal, safety or wefare eghimats ortodomestic munipa,
Commercial, indus, agteutural, recioaona, of oier ut benef ses, ro
stock, wid anima, ode, fh or cher aquat fe, inclaing no imc such
contamination by leration of ve physical chemical obiological propertiesofsuch
ters, or change in temperaut, st, clot ofodor hereof or the discharge of any
ui, gaseous. rdioacive, sokd orive substance no such waers. The department
hal tormine when a discharge consuls pluton, 2 hei dened, and shal
eal standards wheraby and wheel | can be sscerained and determined
hether amy such discharge docs of Goes no conte polluion a herein defined
& “Wators of the Gommonwealt shall beconstrued 0incude any and sil ers, seas,
rocks, lots, mpoundments,diches, water Courses, St sewers, ake, dammed
water pons, pring and al ovr boies of hanesorofarial, conveyanc of surfacee and
Underground watero parts heel, whether natural wih oron he
Boundaries of hs ommomsatn.
26. Base upon heaforementioned facts and circumstances, and formation gathered rough LP
oficial ivestgaton, Your Affant has rosa cause (0 beleve rat Shel pein Company
hs commited eimial vioaons of tv lean Seams Act
40. As may be reared by Rul 507(a)of viewed th Pennsyvania Rules ofCrna Procedure, Chief
Aorey Ganaral Rebecca Franz has and approved te ffdavt ofprobablecouse and
Criminal complaint forfe ssuanceof a summons.
£1. his information is mate subject othe penalties of the Pennsyana Cries Code, 18 Pa GS. §
4904 unworn falifcton to autores,
Jeb 2
Putt, Being Duly S Sunro Accardin, Heceding: »gS er
6 Say that thefact
td the laws, depose 7 a,
set Aagpeth in the Frcenss AFidn sit Fo. Ro%HHt
are (ac gad curve 5 the best HH EE
my Knowledge ndormetion, G— bel: SF FE 4
Jo me. Che hefare we This 141% day of Apal EL
MS orm aisha! Deter toe ATRTES
Doonan oT Fee TTT viiddie: Tast TT

EAR Naghe: SHELL PIPELINE COMPANY LP
=
4. Thiscomplaintconsistsofthe preceding page(s) numbered 1 through
4
SB eC HrPT
ofthe Commonwealth
as listed and hereafter, were against thepeaceand dignity
“Theacts committed by the accused,
AND NOW,onthis date i 0d hosbodproperycomplete ndwrifed

conty hatthcomplain
NRC VFX
#5
Wqtara Dic Coun Naber] Sagat Ey 5
2
im
“0
— Rev.12/21
AOPC 412A - - ot do
rogeth

Shell Pipeline Spill Complaint

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Shell Pipeline Spill Complaint

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COMMONWEALTH OF PENNSYLVANIA POLICE CRIMINAL COMPLAINT (

COUNTY OF:WASHINGTON ‘COMMONWEALTH OF PENNSYLVANIA

GPC 412A — Rev.12/31 ross ZotBo

APC 4124Rev. 07/10 rege

cscommited thaccuse ae desc blowwithech ctofAsso saite sled vated

BO07 Jeotsor m [ewe 1 [ma s a | r— [1] —

[Actsofthe accused associatedwiththisOffense:seeContinuation Page i

40PC 412A -Rev. 07/10 rage

AOC 412A - Rev. 12/21 Page of 4

AOPC 412A — Rev. 12/21 paged of 4,

AOPC412A- Rev. 12/21 paged of 4

AOPC 412A Rev. 12/21 Pegeld of 4b

AOPC 412 Rev. 12/21 pagel] of 46

4. Glossary of terms used in his Criminal Compl, a defied by “Trenciesspedia. con

as ger 20 gallons anon he ROW. Dogwero 0dss

TE. raerooEre OAT

Delong wa ls mesing. Er DeLong. shoud have been repring (hose loses as ey

She reported he DEP pace

Poconding o Erowstn, vc Datong cove oe fom anaged leas’ o desi an IR

Inspects. Grscnloh sae a th HOD Conrinlr (San Larsonwas spose 1051

Teaarements. Gerschalt was provid 10 DeLong

Fr aa ot what eso mart ian

meaan a venve Ee hamptontoo

i espace 2 1 hv eo dompet soma er

ain somstar: ownhs ard ni pln. how mn ey9 pug,HDD help a1

qi, gaseous, rdocive, old o

Doonan oT Fee TTT viiddie: Tast TT

AND NOW,onthis date i 0d hosbodproperycomplete ndwrifed

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