Gas Free Seneca Files to Appeal Federal Regulatory Energy Commission’s (FERC’s) Extension to Crestwood’s subsidiary for Natural Gas Storage Expansion



Joseph Campbell 607-769-4639

Yvonne Taylor 607-342-1278


For Immediate Release

Gas Free Seneca Files to Appeal Federal Regulatory Energy Commission’s (FERC’s) Extension to Crestwood’s subsidiary for Natural Gas Storage Expansion

Cites Failures to Address New Safety Concerns and Regulations on Gas Storage Industry


Today, Wednesday June 15 at 10:46 AM, Gas Free Seneca (GFS) submitted a filing to appeal FERC’s extension of Crestwood subsidiary, Arlington Natural Gas’s permit to expand natural gas storage on Seneca Lake for another 2 years.  The original permit expired before Crestwood began construction, which prompted Crestwood to apply for the extension

“Over 300 comments were submitted by the public citing serious safety concerns and stating that with the glut in the natural gas industry, the expansion was no longer needed for the public convenience and necessity. Both US Senators Kirsten Gillibrand and Chuck Schumer requested that FERC, at the very least, open the issue back up for public comment due to widespread opposition. Despite this, FERC rubber stamped the extension on May 16th of this year,” said Yvonne Taylor, Vice President of Gas Free Seneca.

GFS listed several reasons for the appeal (the full document can be found here: ):

Commenters raised serious safety concerns, based on hazards that were not previously addressed in the Environmental Assessment (EA), and that were not referenced in FERC’s findings.

An Independent Quantitative Risk Analysis (QRA) was prepared from an industry-wide perspective to reach high-level, quantitative conclusions about the degree of risk sustained by a typical salt cavern facility. The GFS appeal states that “In doing so it used methods, calculations and conclusions validated by peer-reviewed, published, scientific analysis which use similar historical databases, employ similar calculations, and reach similar conclusions about the frequency of adverse events.[1] Even if the QRA had limited itself to such a generalized risk assessment, its sober conclusions would be enough to call into question the EA finding and justify reconsideration. FERC, by contrast, has provided no quantitative analysis of overall risk whatsoever to justify its findings.”

The Independent QRA goes further to identify a higher risk level for the caverns on the shores of Seneca compared to other salt caverns, because the caverns are not solid salt but instead are exposed to rock which could lead to gas migration, and because the caverns were never engineered to store anything and are therefore irregularly shaped.[1] The GFS appeal states, “The QRA thereby reasonably concludes, in a manner consistent with such published studies,[2] that the risk associated with Arlington’s project may be somewhat higher than the calculated level.[3]”

The QRA also highlights the fact that FERC failed to address the site-specific situation that the caverns are located in very close proximity to a large lake that serves as the source of drinking water for 100,000 persons.[4] The appeal concludes, “Because there appears to be no pertinent historical experience with which to compare, the risk associated with such proximity cannot easily be dismissed. FERC fails to address this last concern in any substantive way.”

The appeal also mentions the significance of local faulting and seismicity, stating that FERC has not addressed this issue adequately.

Over the last two years the Pipeline and Hazardous Materials Safety Administration (PHMSA) has begun to revise the Pipeline Safety Regulations for gas pipelines[5] where it is proposing to require that operators validate their risk models in light of incident, leak, and failure history and other historical information.[6] GFS states that this is missing from FERC’s incomplete safety assessment.

After the PHSMA proposal had been concluded, Southern California Gas Company’s (SoCal Gas) Aliso Canyon Natural Gas Storage Facility Well SS25 failed, causing a sustained and uncontrolled natural gas leak near Los Angeles, California. The failure resulted in the relocation of more than 4,400 families according to the Aliso Canyon Incident Command briefing report issued on February 01, 2016. On January 6, 2016, California Governor Jerry Brown issued a proclamation declaring the Aliso Canyon incident a state of emergency.  The Obama administration has also announced the creation of the Interagency Task Force on Natural Gas Storage Safety to develop findings in support of federal regulation. “Storing gas in abandoned salt caverns is actually more risky than storing it in depleted oil wells like the one in Aliso Canyon, due to the corrosive nature of salt,” said Joseph Campbell, President of Gas Free Seneca.

The GFS appeal states that, “On February 5, 2016, PHMSA issued an advisory bulletin in the Federal Register (81 FR 6334) to remind all owners and operators of underground storage facilities used for the storage of natural gas to consider the overall integrity of the facilities to ensure the safety of the public and operating personnel and to protect the environment. The advisory bulletin specifically reminded these operators to review their operations and identify the potential of facility leaks and failures, review the operation of their shut-off and isolation systems, and maintain updated emergency plans.[7] Even if there had been no new information provided by commenters on the safety risks of this project, these dramatic changes in condition of fact, heightened recognition of risk, and subsequent instruction for new regulation of underground gas storage call for reconsideration of FERC’s prior findings including, at a minimum, the provision for and analysis of a risk model such as that provided by the cited independent QRA, which has been validated in the light of incident, leak, and failure history and other historical information pertaining to underground gas storage.”

For these reasons, GFS has appealed the Commission’s Order Granting Extension of Time — and requested that the FERC “not permit Arlington to proceed with construction or operation unless or until unless or until the extremely serious safety issues raised by commenters are satisfactorily addressed.”



[1] D. Rob Mackenzie, MD, FACHE: Independent High-Level Quantitative Risk Analysis, Schuyler County Natural Gas Storage Proposal (2014), p10.

[2] Yang (2013).

[3] Mackenzie (2014), p10.

[4] Mackenzie (2014), pp8-9.


[6] Id, Topic E.

[7] Id., Topic K.