The
Forum:
Why I favor
the LPG storage facility
The following letter was sent by Schuyler County Legislature
Chairman Dennis Fagan to David L. Bimber, Deputy Regional Permit Administrator
for the New York State Department of Environmental Conservation's Region
8 regarding the proposed LPG Storage Facility on the west side of Seneca
Lake.
Dear Mr. Bimber:
I am a Schuyler County Legislator representing District
I, which encompasses the Towns of Orange, Reading and Tyrone. As a professional
engineer, who has designed numerous containment systems for sanitary
landfills, leachate storage ponds, wastewater treatment facilities,
etc., I became interested in the proposed Inergy project in 2009 when
the original plans were being formulated. I became alarmed with the
original design of a single liner system for the brine pond and voiced
my concerns to the Town of Reading Planning Board. Based on this interaction,
I became convinced that the Town Planning Board did not possess the
requisite technical expertise to be the SEQR Lead Agency for this significant
project.
I personally contacted the Regional Permit Administrator
in Avon at that time urging DEC to be designated the SEQR Lead Agency
for this project. I am thankful for the DEC Commissioner’s determination
that DEC should be the Lead Agency although the time-frame for this
determination should have been significantly reduced. I am also thankful
that DEC’s landfill experts (Robert Phanenf, P.E., et al) required
a state-of-the-art dual liner containment system be utilized with leak
detection facilities. Based on the current plans, I have no concerns
regarding the containment system and the structural design of the brine
pond.
Much of the initial opposition to the Inergy project centered around
traffic impacts and corresponding harm to tourism which is a major economic
generator in Schuyler County. Much of these traffic concerns were associated
with hydraulic fracturing (fracking) of the Marcellus Shale and the
attendant increase in truck traffic for water and wastewater deliveries,
etc. These concerns associated with traffic-related fracking activities
are misguided since the Inergy project has absolutely nothing to do
with gas extraction activities of the Marcellus Shale. Furthermore the
butane and propane projects that will be transported to the storage
facilities during the summer and fall will NOT be trucked to the facility.
They will be transported to the facility by pipeline or rail. The majority
of the stored products will be transported out of the facility during
the winter heating months (November-March) by rail and truck. The maximum
truck loading capacity is four trucks per hour. The three basic truck
routes leaving the facility are left onto SR 14A towards Penn Yan or
right then either north or south on SR 14. Needless to say, not all
trucks will be traveling south on SR 14 into the Village of Watkins
Glen. At peak loadings of four trucks per hour during the winter heating
season, I don’t see how a rational person can say this adversely
affects our tourism industry. I should also point out that from 1964
to 1984 when TEPPCO stored up to 4 million barrels per year of propane
in the salt caverns, no major traffic or other environmental problems
occurred that I am aware of.
Another issue about which opponents have voiced concerns is the structural
integrity of the salt caverns and the potential for contamination of
Seneca Lake. It is my understanding that a number of salt caverns have
been abandoned under pressure for periods of 20 years or longer. Some
have been re-opened for inspection and there has been no loss of pressure.
This indicates that the brine does not escape or leak from these salt
caverns.
Many commentators have expressed concerns about the growth potential
or future industrialization of this project. The DSEIS states that the
full volume of the two caverns being utilized by Inergy is 5 million
barrels while the project’s storage capacity in the caverns is
only 2.1 million barrels. It should be noted that the capacity of the
brine pond (93 million gallons) is slightly more than the 2.1 million
barrel storage capacity. Hence any increase in storage capacity beyond
2.1 million barrels would require a corresponding increase in the brine
pond capacity. Such a potential capacity increase would trigger a SEQR
review which would be problematic as a SEQR segmentation issue. Hence
I take Inergy at their word that they have no expansion plans for this
LPG storage facility.
Numerous opponents have expressed concerns about the safety of the
operations of the LPG facilities and have called for a quantative risk
assessment (QRA) and more recently a qualitative risk assessment. I
too was concerned about the safe operation of the proposed facility
given its proximity to both Seneca Lake and the Village of Watkins Glen.
I have visited and toured both the NYSEG natural gas storage facility
(which is being purchased by Inergy and is located in the vicinity of
the proposed LPG storage project) and Inergy’s Savona LPG storage
facility. The NYSEG natural gas storage facility utilizes salt caverns
with a working capacity of 1.45 billion cubic feet and has been in operation
since the mid-1990s and is overseen by the Federal Energy Regulatory
Commission. Natural gas is transmitted to and from this storage facility
via buried pipelines. It is my understanding that no major accidents,
leaks or fires have occurred since this facility commenced operations.
The redundant safety features (emergency shut-off valves, etc.) were
certainly evident at this facility. The LPG storage facility in Savona
utilizes salt caverns to store 1.5 million barrels of LPG with four
brine ponds. It has loading/unloading capacity for 20+ rail tank cars
and four truck loading facilities. This facility has been in operation
since the mid-1950s and has had one fire when a drilling rig for a well
caught fire. This did not affect the storage or loading facilities.
The Savona facility was recently upgraded with new control facilities.
Operational safety features include automatic shut-off valves, pressure
relief valves, automatic choke control valves which control flow rates
for loading trucks and tank rail cars, and redundant fail close secondary
valves with pressure pilots. The facility also utilizes emergency shut-down
valves or ESD’s.
I am not a safety expert so I will defer to DEC regarding the need
to conduct a QRA for the proposed LPG facility. However I have heard
some people characterize it as a tool for balancing the potential risk
of a project within the overall economic benefits. That is not my understanding
of the purpose of a QRA. QRA’s identify risk scenarios, quantify
scenario likelihoods and their consequences and interpret the result
for risk management such that safety-related decision-making is risk-informed,
not risked-based. My limited research into QRA’s is that they
are typically completed for large-scale energy projects (nuclear power
plants and radioactive waste storage/disposal sites), aerospace systems,
and chemical and petroleum processing facilities. I am not aware of
QRA’s being completed in New York State similar to the proposed
Inergy Storage project.
Many opponents have questioned the benefits of this project given their
perception of unacceptable risk. The obvious potential benefit is to
help stabilize future propane cost increases. Propane costs in the area
have risen about 30% above last year. Another positive economic benefit
is the creation of 8-10 permanent jobs together with some 50 construction
jobs. For a $40 million project, the permanent job growth is modest
but in this current economy, it certainly is a positive benefit. As
Chairman of the Schuyler County Legislature, I have a somewhat unique
understanding of the economic benefits this project could have on our
economy. The County Legislature is in the process of finalizing our
2012 County budget. With the recently enacted tax cap legislation, counties
throughout Upstate New York are having major financial problems in delivering
their budgets to be in compliance with the tax cap limitations. In Schuyler
County, we were fortunate to experience record sales tax revenues this
year (we are the number one county in the state for sales tax growth
from 2010 to 2011). A significant contributor to this growth is our
tourism industry. Obviously, I would not be in favor of approving this
LPG project if I felt that it would adversely affect our local economy/tourism
industry. Our 2012 budget aggressively assumes our record sales tax
growth will continue. A major consideration for this assumption of continued
sales tax growth is the $20 + million worth of equipment and materials
that will be subject to sales tax for this Inergy LPG project. Another
positive economic factor that this project will create is a significant
($20-$30 million) increase in our tax base. This is particularly important
when one considers that our total countywide assessed value decreased
by some $6 million during the past year.
In summary, I want my constituents to know that I am making this recommendation
to DEC to accept and approve the DSEIS after much thought, research
and investigation. I do not take lightly the letters and comments in
opposition to this project. However, I strongly object to the attempt
by some to connect this project with the fracking of the Marcellus Shale
(MS). Personally, I am opposed to fracking MS in Schuyler County. Our
roadway infrastructure is limited and traffic impacts alone would create
havoc with our tourism industry. However based on current fracking technology,
in order to optimize the horizontal component of hydraulic fracturing,
one needs some 3,000 feet of overburden on top of the MS. Inergy’s
geological maps show that the depth of the MS in the vicinity of the
salt caverns is less than 1500 feet. In fact, virtually all of Schuyler
County (except for small portions of Cayuta and Orange) has less than
3,000 feet of overburden on top of the MS. Hence I believe that there
will be no significant gas extraction of MS in Schuyler County. Based
on my technical experience as a professional engineer for 40 years,
I believe the proposed Inergy LPG project can be constructed and operated
in a safe manner with no significant adverse impact on the environment.
I believe that the TEPPCO operation of propane storage from 1964-1984
in the salt cavern and NYSEG’s natural gas storage in the salt
cavern for the past 15 years shows that these industrial activities
are compatible with a growing tourism industry. I also believe that
the Schuyler County Environmental Management Council will be commenting
directly to your office on the DSEIS.
Thank you for your Agency’s collective environmental review
of this project. I appreciate in advance your consideration of my comments.
Sincerely,
Dennis A. Fagan, P.E.
Schuyler County Legislator, District I
|