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Letter to Gov. Cuomo Re: Oil Padding

September 21, 2016

The Honorable Andrew M. Cuomo
Governor of New York
The State Capitol
Albany, NY 12224


I recently wrote to request that you DENY all regulatory approvals required for proposed Liquefied Petroleum Gas (LPG) and expanded natural gas storage facilities in Reading, NY at a large site owned and operated by Arlington Storage Company, LLC, Crestwood Equity Partners LP, Stagecoach Gas Services, LLC, Finger Lakes LPG Gas Storage, LLC or other interrelated corporate entities.

My letter referenced a series of petroleum and brine pollution releases documented with your Department of Environmental Conservation's (DEC) own spill incidents database profiles. These uncontrolled releases polluted Seneca Lake and caused extensive contamination hazards, including surface water and soil pollution problems that reportedly were not cleaned up to state standards.

See: Letter to Governor Cuomo requesting denial of hydrocarbon storage permits applications for Reading, NY facilities

Previously Undisclosed "Oil Padding" of Salt Mine Cavity Reported by Crestwood/US Salt

Soon after I posted these spill data for public review, I had the honor of receiving a letter from Crestwood and US Salt, LLC.

As you will see below, their letter provides the stunning disclosure that, "three incidents (February 1975, November 1995 and June 1997) relate to industry practices that are no longer practiced (e.g. oil padding in cavity roofs (emphasis added)).1"

The footnote states, "We have assumed a release occurred in December 2003, although the corresponding entry does not clearly indicate that release occurred."

This previously undisclosed and simply shocking revelation has extremely important public health and environmental implications for Seneca Lake and its local residents. That is why I write you today.

Oil Padding in Solution Salt Mines

"Oil padding" is an historic solution mining practice that involves pumping oil into salt mine cavities in order to prevent salt from being dissolved in a way that can cause cavity roof collapses. Improper solution mining of salt has caused extensive and widely recognized problems in the Tully Valley south of Syracuse, including land subsidence and "mud boils."

According to a 1996 scholarly article by a DEC staffperson in the Division of Mineral Resources, named Kathleen F. Sanford, "Two New York operators used fuel oil for roof padding in the early and middle 1970's."

That article also reports, "A proposal for diesel oil injection at a facility where caverns are to be created for natural gas storage has been approved."

Diesel oil and #2 Fuel oil are both highly toxic and persistent when released into subsurface environments. No state environmental regulatory authority would approve such proposals today given the potential for extensive contamination hazards.

Well #49 Fuel Oil Spill

As you will see from various documents that I just obtained through Freedom of Information, the February 17, 1975 spill evidently referenced by Crestwood and US Salt involved a 1,500 gallon #2 fuel oil spill (7580228). This spill specifically references Well #49.

According to a memo prepared by a DEC Environmental Conservation Officer who investigated the spill, "a leak had occurred in well #49, a well containing about 40,000 gallons of #2 fuel oil...(emphasis added)."

"No immediate calculation of oil loss into the lake was known but in my judgment it was appreciable. When I reached the area where the oil was entering Seneca Lake, I could see oil over an area of the lake extending northward for about 1/2 a mile and two (2) to three (3) hundred yards wide."

Most importantly, International Salt Company wrote, "The outer annulus contains #2 fuel oil. This oil was injected into the well and serves as a pad to protect the cavity from vertical dissolving (emphasis added)."

The International Salt Company letter, a memo regarding a proposed assessment of civil penalty pursuant to the Federal Water Pollution Control Act Amendments of 1972, the DEC solution salt mining article and the potentially referenced spill profiles are presented for your review.

See: International Salt Company "Oil Padding in Cavity Roofs" Documents, Reading, NY

Request for Comprehensive Environmental and Public Health Investigation of "Oil Padding" Pollution Threats to Seneca Lake

It is simply inconceivable that this outmoded "oil padding" practice has never been publicly disclosed to local residents or investigated on a comprehensive basis, particularly in light of proposals to establish new LPG and expanded natural gas storage facilities at the Crestwood/US Salt site.

Given that Seneca Lake is one of the most important and revered waterbodies in America, I request that you require a comprehensive investigation to be undertaken of the Crestwood/US Salt site in order to:

1) determine the full scope of any fuel oil or diesel oil contamination which might remain at existing or abandoned solution salt mining wells that could pose a continuing threat to Seneca Lake as well as local residents who drink water from that waterbody;

2) document whether fuel oil or diesel oil was used at the Arlington Gas Storage facility that could pose continuing pollution hazards to Seneca Lake;

3) assess the fate and transport of fuel oil or diesel oil which might have been used for "oil padding" and that might have caused extensive petroleum contamination associated with reported spills with "no apparent source." See: 9508880 and 0270552.

4) clean up the entire Crestwood/US Salt site in strict compliance with all applicable state remediation standards in order to protect water quality in Seneca Lake.

I also request that you investigate "oil padding" concerns at all other salt mines near Seneca Lake and elsewhere in New York where legacy fuel oil or diesel oil contamination hazards might exist.

Please Adopt an Immediate Moratorium on State Approvals for All Gas Storage, Pipeline and Other Fossil Fuel Infrastructure Projects

With respect, this latest revelation further documents that DEC has repeatedly failed to enforce applicable environmental regulatory requirements for mineral extraction, natural gas/LPG storage, fossil fuel transmission pipelines and other infrastructure projects in New York. As as a result, the agency is unable to prevent water quality violations or to clean them up to state standards when they occur.

It is imperative that New York permit no further gas storage, transmission pipelines or other fossil fuel infrastructure projects until the state can fully assure that they will not cause water quality violations. I reiterate my request that you adopt a moratorium on these infrastructure approvals.

I trust that you will find my request self-explanatory, but please do not hesitate to contact me if you have any questions that I can answer.

Thank you for your consideration and for your public service.

Very best regards,

Walter Hang

cc: Honorable Judith A. Enck, Environmental Protection Agency
Region 2 Administrator
Honorable Barbara S. Lifton
Honorable Steven Englebright
Honorable Thomas F. O'Mara
Honorable Charles E. Schumer
Honorable Kirsten Gillibrand