US Salt / Crestwood Letter to Municipal Officials

Rebuttal to US Salt/ Crestwood Letter to Municipal Officials 

Recently, it has come to our attention that Crestwood subsidiary US Salt has been sending a letter to municipal officials referencing DEC claims.  They’re calling it “Straight talk from the DEC“.  The letter is filled with disingenuous misinformation as a last ditch effort to gain support for the gas storage project at their facility.   We are taking this opportunity to give you the REAL straight talk in the following rebuttal.  We urge you to do your homework and not take what an industry desperate for approval has to say without some independent thought and research.  Thank you in advance for your time and consideration.

Claim: DEC staff states that it took “an excruciating look at cavern integrity” before concluding that the salt caverns were suitable for LPG storage.

Fact: DEC staff did not do any testing of the caverns themselves, but instead relied on Crestwood’s own reports. Many of the reports submitted on cavern integrity were signed by Crestwood employee David Crea, a “process” engineer who also writes blogs for pro-fracking websites like Energy In Depth and Natural Gas Now. According to H.C. Clark, Ph.D., retired geologist from Rice University, the lack of integrity of the caverns makes them unsuitable for gas storage. Clark states: “FLLPG understates cavern integrity risks, and the incomplete and inaccurate information in its application leads me to conclude that the galleries cannot be used safely to store LPG, even with the monitoring required in the current draft permit conditions.” /wp-content/uploads/2015/01/Ex.-1-Clark-Report-Exhibits-PUBLIC.pdf

Crestwood hired geologist Don Siegel from Syracuse University to claim that the caverns were safe at the Issues Conference this past February. Siegel is under an ethics review for his support of the gas industry, and is known for taking payment from Chesapeake Energy to use only industry data to compile his review, versus independent scientific information. http://www.syracuse.com/news/index.ssf/2015/05/syracuse_university_fracking_study_chesapeake_american_chemical_society.html

Claim: DEC staff says “it is not a reasonably likely scenario” that storing gas under pressure in unlined salt caverns along a drinking water source for 100,000 people could increase the salinity of the water.

Fact: Our experts say otherwise, which is why so many elected officials who rely on Seneca Lake to provide drinking water to their constituents, have asked Governor Cuomo to deny permits for gas storage in the salt caverns along the lake.  Many neighboring municipalities have followed suit, because they recognize that our growing agri-tourism industry is dependent upon keeping our entire region rural and pristine.  For more information on government resolutions, go to: /?page_id=493

Crestwood cannot explain why Seneca Lake is saltier than any of the other Finger Lakes, or why there was a huge increase in the salinity in the mid 1960s when 2 caverns were first pressurized to store propane. Our independent expert has concluded that the storage may be responsible. Tom Myers, Ph.D., Hydrologic Consultant, writes: “The pressure from the LPG activities is transmitted along the salt formation until it essentially squeezes out high‐Cl [Chloride] groundwater into the bottom of Seneca Lake. The Cl discharges in the mid‐1960s were extremely high, and greatly increased the overall CL concentration in the lake. The currently‐proposed LPG storage in the salt beds would, in my opinion, do the same thing. Since there is no real way to monitor or prevent these discharges, as explained below, FLLPG’s proposed LPG storage should not be permitted in the salt beds.” /wp-content/uploads/2015/01/Ex.-3-Myers-Report-CORRECTED-FINAL-PUBLIC.-1.pdf

Even if there is a remote possibility that Crestwood’s project could cause another big spike of salt contamination, should we take that chance?

Claim: DEC staff states that the view and noise created by a major gas storage and transport hub will “be consistent with a wilderness area” or “a quiet, seemingly serene setting such as rural farm land.”

Fact: A six-track rail siding and truck depot with 1,785 rail cars loading and unloading propane and butane, 2 giant open-air brine ponds and active burning flare stacks, are neither heard nor seen in a typical wilderness area or in a serene setting like rural farmland. The noise from trains on metal tracks, their whistles, compressor station noise, trucks, jake brakes, etc. travel for miles over open still lake water. In our independent Noise Report conducted by

Sandstone Environmental Associates, Inc., A. Brook Crossan, Ph.D., P.E.  states: “In my opinion as an environmental engineer with more than 40 years’ experience in conducting noise studies, environmental impact statements, and environmental assessments in over 30 states, residents of the Seneca Lake community and tourists visiting the area are likely to suffer significant and unmitigated noise impacts from the Project, notwithstanding the mitigation measures proposed by the Applicant and conditions that NYSDEC proposes to attach to the Applicant’s permit, if the permit is granted.”  /wp-content/uploads/2015/01/Ex.-4-Sandstone-Report-Exhibits-PUBLIC.pdf

The visual impacts of this project right now, even before state approval of LPG storage project, is not compatible with the viewshed from the east side of Seneca Lake and the signature stop along the Seneca Lake Scenic Byway, Hector Falls /?attachment_id=557 and is in no way consistent with a wilderness area or rural farm scenery.

Claim: Truck traffic “wouldn’t be significant under any circumstance.”

Fact: That depends. In a letter to the DEC in December 2014, Crestwood stated that all of the propane and butane will be leaving the facility via pipeline, thus there would be no trucks involved in transporting product.  /wp-content/uploads/2015/05/Transportation-Allocation-Highlighted.pdf

Nevertheless, they have not yet eliminated the truck depot from the DSEIS. If they intend to use trucks, then our already clogged rural roads will experience increased truck traffic. If they choose not to use trucks, then the propane is not intended for local use and will be sent to Selkirk, New York and destined for New England states and possibly export. 600,000 barrels of butane is also headed to refineries in New Jersey and Philadelphia.

Claim: DEC staff claims there is “no significant and substantive issue related to public safety regarding this project.” DEC attempts to discredit the independent expert who compiled the safety analysis for the project by calling him a “retired local physician.”

Fact: Dr. Rob Mackenzie is the retired President and CEO of Cayuga Medical Center, where he specialized in performing risk analyses using industry-standards, methods, and protocol. Dr. Mackenzie employed the most widely used criteria for reporting major-accident hazards involving dangerous substances, which were promulgated by the European Union in Appendix VI of the SEVESO II Directive (Dir. 96/82 in 1999). These were adopted in 2000 by Marcogaz, a consortium of eight companies involved in underground storage activity, for use in a database for major accidents. The scope of the Marcogaz database is concerned with all parts of the infrastructure at storage plants: wells, compressors, treatment and measuring facilities, and pipework systems that have led to any particular incident.

Dr. Mackenzie led statewide CEO taskforces to improve safety performance, leading to the 2010 recognition of Cayuga Medical Center by Consumer Reports as New York State’s safest hospital. His safety and risk assessment experience includes:

• Chair of VHA-Empire State Healthcare CEO Safety Network
• Organizational, community, hospital, and industrial safety and risk assessments (both quantitative and qualitative)
• Training in high-reliability science, and
• On-site evaluations of safety practices at high-reliability medical and industrial sites, including Sentara, Palo Verde nuclear facility, and NASA.

Dr. Mackenzie concludes that: “The risk of a salt cavern facility event of serious or extremely serious consequence within the county in the next twenty-five years, including both baseline and incremental risks, is more than 40 percent.” /wp-content/uploads/2015/01/Ex.-2-Mackenzie-Report-Attachments-PUBLIC.pdf

The recently approved Schuyler County Emergency Management Plan addresses two of the more likely accident scenarios of the proposed project. One involves a propane truck accident overturning at the base of Route 14 (several accidents involving tractor trailers have already occurred there, most recently on March 7, 2015), where the Harbor Hotel would be enveloped with explosive propane. The ignition of a car starting or a cigarette lighter would likely leave first responders with nothing more than a recovery mission as a response. The other incident involves a train derailment on the 80 year-old trestle that spans the Watkins Glen Gorge. Tourists would be trapped in the gorge with no escape, causing mass asphyxiation, and in the event of ignition they would be incinerated. The propane vapor cloud would likely funnel into the center of the Village of Watkins Glen leveling the Schuyler County Courthouse and beyond.

Claim: The DEC staff claims that the wine and tourism industry would not be impacted by the proposed project, stating that the agri-tourism industry has grown in the midst of existing gas storage.

Fact: Crestwood’s plan for expansion is not the same as the existing gas storage facility.  Currently, there is 1.5 billion cubic feet of methane in salt caverns, and Teppco stores propane in engineered, shallow rock caverns. Neither of the existing facilities requires expansive brine ponds, compressor stations or a train or truck depot. Crestwood’s expansion plan is designed to turn the western shore of Seneca Lake, in its own words, into a “gas storage and transport hub for the Northeastern United States.”

Currently there is a fine balance between industry and tourism in the area. The proposed expansion and its related above-ground infrastructure is something entirely different and would tip the scale from balanced coexistence to an industrial landscape that is not compatible with the comprehensive plans, the land use laws, or the vision that so many have worked to achieve in the Finger Lakes. That is why 325 regional businesses and 24 municipalities (Counties, Towns, Villages and Cities, including the Cities of Geneva, Rochester, and Syracuse) officially oppose Crestwood’s proposal. This is not business as usual, and local business owners and elected officials know it. To read more about the threat Crestwood’s project poses on our community’s character, go to: /wp-content/uploads/2015/01/Ex.-5-Flad-Report-Exhibit-PUBLIC.pdf

Claim: Recently, in a letter sent to Municipal Officials, Crestwood claims that the project will bring in 17 permanent jobs.

Fact: In the Crestwood-prepared DSEIS, they claim that 8-10 permanent jobs will be created by the project. If the truck depot is not going to be operating, as Crestwood claims in its letter to the DEC (see above) then those jobs will be eliminated. Which is it: 8-10 jobs? 17 jobs? Regardless, if the project drives our $3 billion annual tourism industry away, as visitors choose more serene venues for their vacation, how many jobs will be lost?

Claim: Crestwood claims that “having more propane available in state helps customers avoid price spikes and shortages.”

Fact: Not if the propane is sent via pipeline to New England and for export, as Crestwood tells DEC in their Transportation Allocation Letter. Further, there is no need for propane regionally.  Three facilities already exist within a 60-mile radius of Watkins Glen, New York that store 3.5 million barrels of propane, enough to heat 600,000 homes. In New York, only 225,000 homes rely on propane for heat. Crestwood admits in their Transportation Allocation Letter that 100% of the propane stored at this facility will leave by pipeline and go to a supply terminal in Selkirk, NY that serves New England and the Mid-Atlantic states.

The Finger Lakes Region does not need to be the sacrifice zone for gas industry export. Additionally, propane costs are not based on proximity, they are market-driven.

Final Words: Why is the DEC staff siding with industry? The DEC staff is defending its work to save face, and wants to avoid costly litigation. It is the DEC Division of Minerals’ mandate to assist in the development of mineral resources in the state. That is why they were in collusion with the gas industry and were ready to allow fracking in New York State, until Governor Cuomo stepped in.

Those of us who live here or care about the Finger Lakes can think for ourselves. We have independent expert witnesses, with no ties to Industry, outlining the risks. Let’s think about the myths and misrepresentations that the DEC and Crestwood, who are clearly in collusion, are using before we allow them to make a mistake that could threaten our homes, livelihoods, safety, and water for generations to come.

Join us in doing the homework, and if you think Crestwood’s project is a bad idea, please contact Governor Cuomo /?page_id=1058 and ask him to deny permits for gas storage on Seneca Lake. Even the Town of Reading, the small town where the gas storage project is being proposed, has language in their Comprehensive Plan that suggests it should not be approved: “The purpose of these regulations is to maintain not only the rural appearance and physical character of the Town, but also its rural way of life and social environment. This rural tradition is one in which landowners are free to use their property in any manner that does not harm their neighbors or the Town or region as a whole.”

The region’s future as a whole should not be determined by one town’s decision. It is our responsibility as a community to be good neighbors to one another and stand united in our work to

preserve the beautiful Finger Lakes for generations to come. Please help us send Crestwood back to Texas. For more information, please go to: www.gasfreeseneca.com