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HomeMy WebLinkAbout2016-Cargill_proposal_comment_period-1FROM TOWN SUPERVISOR: Cargill Mine Shaft proposal - Comment Deadline 12/9/16 NYS DEC is accepting comments through December 9, 2016 on Cargill's proposed new mine shaft on 12.3 acres at 1001 Ridge Rd in Lansing. Below is the information from the public comment announcement. More information is enclosed. For more information contact Darby Kiley (kiley@ulysses.ny.us or 387-9778 Ext 222) Applicant: Cargill Incorporated 15407 McGinty Rd W Wayzata, MN 55391 -2399 Facility:Cayuga Salt Mine 191 Portland Pt Rd South Lansing, NY 14882 Application ID: 0-9999-00075/00001 Permit(s) Applied for: Article 23 Title 27 Mined Land Reclamation Project Description: This is a second Notice due to public request for an extended comment period. Cargill, Inc. ("Cargill") proposes to expand the surface operation by adding 12.3 acres to the Life-of-Mine area, including a new mine shaft ("shaft 4") and infrastructure to be constructed in support of the new shaft, on land owned by Cargill. The modification application involves the construction of a surface access and ventilation shaft because of safety precautions, Mine Safety and Health Administration (MSHA) regulations and the increasing distance from the current underground operations to Cargill's main access and ventilation shaft as progresses to the north and west. The proposed final reclamation plan states that shaft 4 will be decommissioned, which involves removal of any piping or operating systems from the shaft, injecting cementitious low- permeability flowable fill that will permanently seal the shaft and filling the uppermost eight to ten feet of the shaft with a high-strength concrete plug. The surface facilities will remain to provide office and/or commercial facilities for future use. The facility is located at 1001 Ridge Road (NYS RTE 34B), Town of Lansing, Tompkins County. Availability of Application Documents: Filed application documents, and Department draft permits where applicable, are available for inspection during normal business hours at the address of the contact person. To ensure timely service at the time of inspection, it is recommended that an appointment be made with the contact person. State Environmental Quality Review (SEQR) Determination: Project is a Type I action and will not have a significant effect on the environment. A coordinated review with other agencies was performed and a Negative Declaration is on file. SEQR Lead Agency: NYS Department of Environmental Conservation State Historic Preservation Act (SHPA) Determination: Cultural resource lists and maps have been checked. The proposed activity is not in an area of identified archaeological sensitivity and no known registered, eligible or inventoried archaeological sites or historic structures were identified or documented for the project location. No further review in accordance with SHPA is required. Opportunity for Public Comment: Comments on this project must be submitted in writing to the Contact Person no later than Dec 09, 2016. Contact: Joseph M Dlugolenski NYSDEC Region 7 Cortland Sub-Office 1285 Fisher Ave Cortland, NY 13045 (607)753-3095 DEP.R7@dec.ny.gov Project location maps Project site at 1001 Ridge Rd Project site at 1001 Ridge Rd 1 November 30, 2016 Chris Dennis Environment Foundation 893 Cayuga Heights Road Ithaca, NY 14850 USA 1-607-227-5172 Re: Need for Environmental Impact Statement for Cargill’s Mine Shaft 4 Dear Resident of Tompkins and Neighboring Counties: The Chris Dennis Environment Foundation supports efforts to protect Cayuga Lake. I write to request that you join me in urging the New York State Department of Environmental Conservation (DEC) to require Cargill, Inc., to conduct a publicly-available Environmental Impact Study (EIS) for its proposed $47M “Mine Shaft 4” project in the Town of Lansing. Last June, DEC issued a poorly-publicized “negative declaration,” determining that this complex project will “not have a significant effect on the environment” and that a Draft Environmental Impact Statement [DEIS] would not be required. This finding runs counter to fact and logic. As you may know, Cargill plans to locate its new Shaft 4 in a bucolic east shore landscape in the Town of Lansing, almost 4 miles northwest of the three existing mine shafts at Portland Point. Cargill intends to ream a 2500’ deep, 18’-diameter shaft that will connect to a two-mile tunnel connecting to its mining reserves under the lake (see Map 1). This project is a source of concern for at least five reasons. First, there is an under-studied possibility that the shaft penetration will release major amounts of natural gas into the atmosphere with non-trivial climate change implications. DEC’s negative declaration states that the released methane would be dissipated into the mine where it presumably would not have climate change effects. In fact, it would mostly be vented to the atmosphere from Cargill’s upcast shaft at Portland Point. Cargill already vents methane releases from Cayuga Mine without reporting these releases to the EPA’s Air Emissions Inventory (EIS) or EPA’s Greenhouse Gas Emissions (eGGRT) data base. Second, it is proposed that the Shaft 4 opening will be covered with a 93’-high building; that’s roughly the equivalent of nine stories and well over the height of any structure in the region. It will be seen from viewing sites, public and private, for several miles up and down the west side of Cayuga Lake. As Cargill continues to mine northward up the lake, Cargill can apply to upgrade the Shaft 4 permit to allow Cargill to remove and ship salt from this location. Imagine an ugly industrial Portland Point landscape directly opposite from Taughannock Park and Frontenac Point. Cayuga Lake’s cachet as center for nature lovers and the Finger Lakes Wine Industry could be spoiled indefinitely. Third, reaming the hole for Shaft #4 could establish an unintended connection between an aquifer beneath Cayuga Lake and the even lower Cargill mine. Such a connection caused the Retsof Mine—the largest salt mine in the U.S.--to collapse and flood in 1994-95. Dr. John K. Warren, an eminent evaporite geologist who has reviewed the Shaft 4 proposal is concerned that 2 by choosing to ream the shaft from the bottom, Cargill might hit an unexpected fracture in the aquifer that could result in an uncontrollable release of water, flooding the mine. Fourth, and most significantly, the bedrock separation between the salt strata and the overlying the lake gets thinner as one moves north up the lake due to the up-dip of the geological strata. Dr. Warren estimates that at Milliken Station as little as 150 meters (≈500 feet) of bedrock separate the bottom of Cayuga Lake basin from the top of the salt layers. As can be seen in the attached fact sheet, this is less than the 600 feet of separation that existed at Retsof. NYS legislators have worried since at least 1995 that this separation is insufficient for our safety. Fifth, Cargill intends to store millions of gallons of water leaked from Shaft 4 in its mine. DEC has asked Cargill how this storage of additional water in the mine will affect global mine stability? Cargill’s consultant, Spectra Environmental Group, essentially replied, “Cargill is already doing it.” DEC and the public need scientific answers to key questions key questions, such as, at what point might leakage from Shaft #4 yield so much water that underground storage in a salt-soluble environment becomes hazardous? As can be seen in the Google Earth image below, Cayuga Salt Mine is a mine flanked by nearby salt mine failures, namely, a century of “wild brining” failures in the Tully Valley roughly 40 miles to the northeast, the failure in 1976 of the Himrod room-and-pillar salt mine about 12 miles due west of Milliken Station on Seneca Lake, and the failure in 1994-95 of the Retsof Salt Mine located about 67 miles northwest of Milliken Station. How could DEC waive the Shaft #4 EIS in light of this calamitous salt mine record in our state? Subsidence following the flooding of the Retsof Mine damaged roads, bridges, and buildings. The mine’s insurers eventually paid $20M to Livingston County and to the DEC for the “purchase” of the freshwater above the mine that is now becoming permanently salinized. We have no idea how much financial assurance the DEC has required Cargill to place in escrow against environmental damage caused by mine failure. But, we do know that 2013 data from Cargill’s consultant, RESPEC, indicate that the bedrock thickness numbers near Shaft 4 may be significantly less than the 600 feet that existed at Retsof. The public deserves to know if the Retsof history may repeat itself at Cayuga Lake. 3 The only way to “get to the bottom” of this unacceptable situation is to request that DEC reconsider its negative declaration on the Shaft #4’s potential impacts. A bona fide environmental impact assessment of these impacts will make transparent and public what is now private information held by Cargill. DEC agreed to extend the comment period on its decision to December 9th, 2016. To assist your letter, I attach a fact sheet on each of the five concerns listed above. Use these or others as your talking points, but please don’t delay in sending your letter to: Joseph M Dlugolenski NYSDEC Region 7 Cortland Sub-Office 1285 Fisher Ave Cortland, NY 13045 DEP.R7@dec.ny.gov Re: DEC Application ID#0-9999-00075/00001 (Cargill Mine Shaft #4) Our letters are the best way I know to build trust in NYS government and assure a safe future for Cayuga Lake. Thank you very much. Sincerely, John V. Dennis, PhD CDEF President 1 Cargill Mine Shaft #4 Potential Environmental Issues Salinization of Cayuga Lake In 1994 portions of the Akzo-Nobel rock salt mine in Livingston County (“the Retsof mine”), the largest salt mine in the U.S., reportedly collapsed due to a combination of overly-wide mining spans, the introduction of the use of smaller yielding pillars, and unanticipated weaknesses in the overlying rock layers. The collapse led to flooding of the entire mine by the local aquifer and significant ground subsidence that damaged roads, bridges, houses, and farmland. Subsequently the local aquifer--now in communication with the salt layers--became salinized and non-potable. In 1995, legislative hearings raised concern that a similar failure might occur in Cargill’s Cayuga Salt Mine under Cayuga Lake because of similar geology and mining techniques. Assemblyman Martin Luster stated in the hearings that “I have no desire to have, in my district, what might become the world’s third largest in-land body of salt water.” Could such a disaster really happen here? Geologists and company officials have disputed the similarities and differences between the two mines, but the public deserves to hear both sides of the story. Dr. John Warren, an independent expert on salt geology notes the poor public documentation on the highly-fractured rock around the Mine Shaft #4 location. He is concerned that in reaming the hole for Mine Shaft #4, Cargill could establish an unintended connection between an aquifer beneath Cayuga Lake and the mine itself. Mine flooding—whether accidental or as part of a planned abandonment strategy--could eventually lead to gradual or sudden subsidence of the lake bed and/or communications between the flooded mine and Cayuga Lake. The result could be the same sort of salinization tipping point that is happening at Retsof. This time, however, it would be lake salinization, not aquifer salinization. Worse, the deepest aquifer between the mine and Cayuga Lake is already salinized, so our safety margin could be even less, especially if “trough subsidence” caused by salt mining pressurized the saline aquifer resulting in brine flows into Cayuga Lake. No data on subsidence of the lake floor over the mine are publically available. However, a group of 22 subsidence monuments over earlier salt mining under the Town of Lansing indicate subsidence of greater than 1 foot in 35 years. How likely is a catastrophic lake salinization scenario? Dr. Warren says we won’t know without further public information, which could be provided in a DEIS process. What is Adequate Bedrock Separation? A consultant to the DEC, John T. Boyd & Co. included this table in a 2002 review of Cargill’s Mined Land Use Plan: Cayuga Mine Retsof Mine Total Depth (ft) 1,850 1,100 Lake Depth (ft) 400 0 Sediment and Glacial Till Thickness (ft) 650 500 Bedrock Thickness (ft) 800 (min) 600 Panel Width (ft) 488 670 Pressure Arch Height to Width Ratio 1.6 0.9 Pressure at Top of Arch (dead load) (psi) 850 520 Source: John T. Boyd & Co. 2002. Review of the Mined Land Use Plan, Cayuga Mine, Cargill Inc., Seneca and Tompkins Counties, New York. Prepared for the NYS DEC. p. 5 2 According to Dr. Warren, 2013 stratagraphic data from Cargill consultant RESPEC indicate that at the latitude of the proposed Shaft 4 project, bedrock separation may be as little as about 500 feet, in other words, significantly below the Retsof figure of 600 feet. Note also that due to greater depth, dead load pressure on top of arches in the Cayuga Mine is estimated to be 63% higher. Greenhouse Gases Based on the amount of natural gas encountered in Cargill’s test hole at the proposed Shaft 4 site, as much as 4.85 million cubic feet 1 of natural gas could be released during the year or more required to ream and seal the shaft. DEC’s negative declaration makes no mention of climate change impacts, and gives the erroneous impression that methane leaking from the Shaft 4 might actually be contained within the mine. In fact it will be vented from Cargill’s shaft at Portland Point within days. (Cargill is already venting methane from the mine at their Shaft 3, but sends no information to the EPA.) The public deserves to hear what the effects of that natural gas leakage will be. Viewshed DEC’s negative declaration states that “photo simulations” from Taughannock Park and from Frontenac Point indicate that the planned 93’-high shaft building and two other buildings were either “obstructed from view by vegetation or topography or were barely discernible.” No mention is made as to whether the photo simulation was done in summer or winter. However, an independent leaf-off season viewshed map indicates that the tower will be visible from at least three miles of Cayuga Lake’s west shoreline in Tompkins County, and from at least 2.5 miles of west shoreline in Seneca County. Thus far, we know of no landowners in Seneca County that have even been notified of the proposed project. The nine-story shaft building would be located within a quarter of a mile of Route 34B and it is probable that the top seven stories will be visible from Route 34B and from large areas of the lake, completely changing the ambiance of this scenic rural landscape. The County’s Unique Natural Area No. 24 lies just west of the project site. The public should hear about the adverse effects the project will have on the viewshed. Industrialization The land on either side of Route 34B north of Salmon Creek is zoned agricultural/residential and currently has no hint of industrial activity. Should Cargill apply to expand its permit, much of their salt removal and processing at Portland Point might move to this site. Cargill’s facility on Portland Point is an eyesore on lake’s 85+ mile circumference. To place a similar facility directly across from Taughannock Park would be a major environmental impact. The public deserves to know if this level of industrialization will be likely if this project is approved. Water storage Cargill plans to store all the water that leaks from the mineshaft in the mine itself. However, if the volume of water is large enough, any undersaturated brine will erode the mine support pillars, jeopardizing mine safety--especially if a fire, explosion, earthquake, or pipe or dam failure occurs. Secondly, the presence of fluid storage areas within the mine raises ambient humidity levels. Higher humidity in the mine increase rates of salt creep 2, pillar yield and room closure. Increasing rates of room closure tend to foreshadow ceiling collapses and progressive collapse of rock 1 We have annualized gas production based on this statement on page 2 of RESPEC’s 2013 report, Cargill De-icing Technology Lansing Mine, Corehole #18 Stratigraphic Test Hole, Installation and Data Collection, “The estimated gas production rate was 13,300 cubic feet per day (cfd).” However, it is possible that this daily production rate could be more of a “burp” rather than a sustained rate of release. 2 Salt is a plastic material that will move slowly (creep) under large pressure differences. “Room closure” refers to the inevitable movement of ceiling and floor toward each other in salt mines. Reportedly, Cargill abandoned gathering room closure information in the eastern section of Cayuga Mine in 2008 due to access issues. 3 layers between the mine and any bodies of water located above the mine. Mine Future The whole purpose for Mine Shaft #4 is to permit safe mining further up the lake. But even at current mining locations, Dr. Warren calculates that as little as 500 feet of bedrock separate the bottom of the freshwater Cayuga Lake basin and the top of the salt layers. He is concerned that this separation-distance is not sufficient protection between the lake and the mine. The further up the lake Cargill mines, the narrower that separation becomes, since the salt layers are slanted. And as noted above, significant mine roof subsidence has already started. Are we headed for a Retsof event, or worse? This issue should be openly explored. Decommissioning When a high-level Cargill official was recently asked how Cargill will eventually close down the mine, the official thought for a while as if this were not a question he’d fielded previously. He then indicated that the mine would “probably be flooded to maintain hydrostatic pressure.” Flooding the mine creates a massive reservoir under the lake filled with billions of gallons of saturated brine, three times the salinity of sea water. This inevitably leads to a certain amount of pillar dissolution and weakening. This weakening in turn could result in the sort of seismic subsidence event that occurred at Retsof--resulting in hydraulic connectivity with both the overlying brine aquifer and with Cayuga Lake. If this happens, brine could gradually or suddenly discharge into the lake as trough subsidence along the length of the lake forces the brine out of both the mined spaces and the overlying brine aquifer. Examples from Dr. Warren’s report suggest that the worst-case scenario, resulting from such subsidence and brine discharge into the lake would be a geologically unstable shoreline, the sinking of roads and buildings, the death of aquatic life, and non-potable lake water. The public should be involved in discussing the future of our mine and our lake. Process Cargill maintains that the public has no right to look into many of the above subsurface issues such as salinization, water storage, mine expansion, and decommissioning through the DEC’s DEIS process. They claim that a competitor could use this information to their disadvantage despite the fact that they have been the sole salt mining company on the lake since 1970. Another issue may be that Cargill still disputes whether the DEC has jurisdiction over its subsurface mining activities. If this dispute is on-going, it may explain why the DEC has never required Cargill to perform an EIS on any aspect of the mine’s operation over the past 46 years. When in June 2015, DEC approved a further 150 acre expansion of Cargill’s permitted mine area there was no mention in the “negative declaration” that this expansion area was needed to construct a two-mile underground tunnel and associated mine management infrastructure along this entrance tunnel such as air handlers, electricity transmission hardware, a repair shop, a garage for staff transport vehicles, emergency first aid, communications, and so forth. In the “description of action” it is written that “the reviewed Life of Mine (LOM) expansion area is 150.3 acres, and there are no other proposed changes to the currently permitted operation.” We can think of three reasons why Cargill wanted the DEC to allow them to “segment” this Shaft 4 project into an expansion of mining reserves application in 2015 and the construction of a 2500’ deep shaft application in a later year. First, gross revenues from the sale of salt from the additional150 acres of minable reserves could well exceed the cost of the entire Shaft 4 project which is reportedly $47M. Presumably, the Empire State Development Fund would not look favorably on a request for an $8M subsidy if the 4 fund’s directors understood that this Cargill project might be self-financing. Second, DEC has raised the question with Cargill as to whether Cargill’s plans to store several million gallons of waters leaking from Shaft 4 in the mine may adversely increase humidity levels in the mine. Third, the construction of Shaft 4 will give Cargill the ability to mine further to the north for another thirty years. Such mining would go further and further into areas with thinner and thinner bedrock separation when at Milliken Point it appears that Cargill will already be operating with less bedrock separation than existed at Retsof Mine. Only by segmenting the project into two pieces, an innocuous expansion of mining area by a minor amount and a “potential future air shaft” could Cargill be able to argue that these were two separate projects. And, by the time the public became aware of the project on the surface, it would be too late to comment on any adverse impacts that Shaft 4 might have regarding global mine stability and safety. We believe the public needs more disclosure, not only of any and all risks associated with the construction of the proposed new shaft, but also disclosure about the risks associated with the additional thirty-plus years of mining under the lake that the shaft would enable within the problematic northern reserves. When our lake is concerned, we can’t be too careful. Thank you for urging the DEC to require Cargill to submit a DEIS.