Saturday, July 30, 2016

Tar Sands Lexicon -- by BH

Thanks for the insistence on correct language, Mary.
I can't tell you how many times I've tried to correct people on this.
Even very respectable outlets like DeSmog gets this wrong sometimes.

Here is a Tar Sands lexicon, authored by me (Bill Huston):
  • Oil = a very overloaded term. Generally, "a slippery liquid". Could mean crude oil, fuel oil, lubricating oil, or even edible products, such as corn oil, cottonseed oil, olive oil, salad oil.

  • Crude Oil = Natural Product. Broad-spectrum mixture of hydrocarbons
    • from the lightest NGLs (Natural Gas Liquids, a/k/a "condensate")
      from C3/Propane to C10/Decane "Natural Gasoline"
    • middle weight hydrocarbons from Kerosene to Diesel (C10-C20)
    • heavy oils, lubricating oil, fuel oil, greases, wax (C20-C50)
    • extra heavy tars (C50+) Bitumen (Asphalt, Pitch) Semi-solid 

  • Tar Sands = Geological formation. Largest is in Alberta, Canada. Raw material (bitumen+sand). NOT A SHIPPABLE PRODUCT. Requires cleaning and processing before being further refined.

  • "Oil Sands" = a very misleading term. "Tar Sands" is more accurate. The Tar Sands formation in Alberta contains very little of what what might be called "crude oil".

  • "Bitumen" = a low-grade, extra heavy hydrocarbon. Bitumen is a SEMI-SOLID, and thus is not a "slippery liquid". The terms "oil" or "crude oil" often used for bitumen are inappropriate.  Bitumen can be a natural product, or a residual product of crude oil refining.

    Bitumen is a component of crude oil.  BITUMEN ITSELF IS NOT THE SAME AS "CRUDE OIL". Bitumen is the raw material of interest in "tar sands".  Bitumen is not a product which can be easily shipped, except in a rail hopper car like coal. Prior to modern times, Bitumen has been considered a refinery WASTE PRODUCT. Old refinery diagrams called it "residuum" or "bottoms product". It was used principally to seal roads, and roofs as a beneficial use. 

    Bitumen cannot be shipped in a pipeline without being diluted with a solvent, generally, NGLs.  Synonyms: Asphalt, Pitch, Tar

  • "Upgraded Bitumen" = Prior to modern times (~1990s), it had very little use as a refinery input, since it contains very little of the most valuable light and middle-weight hydrocarbons used for fuel, lubricants, and as inputs to the petro-chemical industry. It is only because most of the easy-to-get crude oil on planet earth is depleted, that this low-grade hydrocarbon is being used as a refinery input. It is only through extreme-technology that bitumen can be used as a source of refined products (such as gasoline), as it must be "upgraded".

    Upgrading bitumen is an extremely expensive process, both in terms of capital -- the Suncor Upgrader in Ft. McMurray Alberta cost ~$12B --, it is also expensive in terms of energy inputs. Upgrading bitumen requires massive amounts of other fuel such as natural gas or propane, as a heat source, at extreme energy levels (somtimes 850 °C or higher) to smash the long hydrocarbon molecules into smaller components.

  • "Diluted Bitumen" = a/k/a, "DilBit", is a SYNTHETIC PRODUCT, raw bitumen diluted by NGLs. Diluted Bitumen can be thought of as a low-grade synthetic crude oil, however it has a "hole in the middle". It is made of light hydrocarbon diluents, and extra-heavy bitumen. But very little of the middle-weight hydrocarbons found in natural crude oil. Diluted Bitumen IS NOT "CRUDE OIL"!!!  They are taxed/regulated differently, refined differently, and are chemically different.

  • "SynCrude" = Synthetic Crude. SynCrude is a trademarked product, a higher grade form of synthetic crude than Diluted Bitumen. SynCrude is made by blending Diluted Bitumen with middle-weight hydrocarbons created by Upgrading Bitumen.  There are various other blends such as "SynBit".
I hope this is helpful, as I agree with Mary that it is CRITICAL we use correct, descriptive, and accurate language.

BH


On Sat, Jul 30, 2016 at 9:52 PM, 'Mary Finneran' via PilgrimPipeline <pilgrimpipeline@googlegroups.com> wrote:
Doesn't take a whole lot of imagination to see a shortcut being taken past Lake Champlain to Albany.  Notice one route leads to Linden.  By the way, Cassellini, the lobbyist for Pilgrim from Albany, said recently in Rensselaer that the Pilgrim Pipelines would never transport tar sands, but no pipeline can!  It can take the diluted bitumen produced from tarsands however!  Language is critical! 

Any which way they can...

Whale breaches near oil tanker. (photo: NOAA)
Whale breaches near oil tanker. (photo: NOAA)

Tar Sands in the Atlantic Ocean: TransCanada's Proposed Energy East Pipeline

By Joshua Axelrod and Anthony Swift, NRDC
28 July 16
 
ransCanada—which was thwarted in its effort to drive Keystone XL through America's heartland—is now pursuing a project that would effectively create a waterborne tar sands pipeline that would threaten the U.S. Atlantic and Gulf coasts. This proposed Canadian pipeline, Energy East, would bring as much as 1.1 million barrels per day of mostly tar sands oil from Alberta to Canada's eastern seaport of Saint John, New Brunswick. From there, nearly 300 supertankers per year would form a high-risk "pipeline" down the entire U.S. Eastern Seaboard, from the tip of Maine to the Florida Panhandle, around Florida's peninsula, and on to refineries along the Gulf Coast.
The tankers—representing a 300 percent increase in crude oil traffic in Nova Scotia's ecologically critical Bay of Fundy—would pose a significant threat to endangered marine mammals and regionally critical fisheries in the form of deafening ocean noise and an increased risk of oil spills and ship strikes. Given that the National Academy of Sciences has concluded that emergency responders lack the tools to effectively contain and clean up diluted bitumen (the most common form of tar sands crude), the risk of a tar sands spill threatens vibrant and irreplaceable marine habitats all along the East Coast—along with economies that depend on them. The pipeline would also bring a significant increase in carbon pollution, equivalent to the annual emissions of as many as 54 million passenger vehicles, and lock in high-carbon infrastructure expected to operate for at least 50 years.
Despite the significant risks posed by Energy East, our analysis reveals that the scope of the forthcoming environmental review by Canadian authorities is sorely lacking. In this report, we offer a series of recommendations for reforming the current regulatory review process and propose several critical safety regulations for the United States and Canada, including:
  1. Imposing a tar sands oil tanker moratorium in U.S. and Canadian waters until appropriate spill response techniques are developed to address a diluted bitumen spill into water.

  2. Improving tanker operations to ensure that any impacts to marine mammals and ecosystems would be at a minimum.

  3. Amending Canada's Environmental Assessment Act to improve public participation in the review process and ensure consideration of the environmental, health, and economic impact in areas ranging from where the oil is produced to its final destination.

  4. Getting the United States involved in the review process, ensuring that risks to shared resources are analyzed.

  5. Permanently protecting especially vulnerable and special ocean regions to eliminate, as much as possible, the threat oil spills and other marine accidents pose to these critical areas.
(photo: NRDC.org)
 


 
Jail the corporate criminals who kill, steal, lie for profit.
http://www.frackbustersny.org/missionvision.html

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--
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May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

Friday, July 22, 2016

Press Release: DEC Grants Comment Extension for Endicott Pollution License



------ FOR IMMEDIATE RELEASE ------

DEC Grants Comment Extension for Endicott Pollution License
Friday July 22, 2016

ENDICOTT, NY -- Yesterday, the NYS Department of Environmental Conservation issued the following statement:
Due to the enhanced public interest in regards to the i3 draft Permit, NYSDEC will hold a Public Information Session and Legislative Hearing along with extending the public comment period.  The Department is working on scheduling a date and location but anticipates the Public Information Session and Hearing will be held in mid-September and the public comment period will be extended until the end part of September.  Please share this news with others who may not be on this distribution.  Once the details are finalized, a formal announcement will be made.

Timothy DiGiulio, P.E., Regional Water Engineer
New York State Department of Environmental Conservation, Region 7
P: (315) 426-7500 | tim.digiulio@dec.ny.gov

While Concerned Citizens of Endicott (CCoE) are pleased in this small delay in the rubber-stamping of this permit, we see (and smell) the trucks of toxic landfill leachate are still coming.

"I'll be happy when the trucks stop bringing poisons to a village which is already a TCE contaminated Superfund site", said Mark Bacon, of CCoE.

Bill Huston, also of CCoE adds, "These trucks have been dumping 80,000 gallons of poison per day in Endicott since 2011. This waste was never allowed under i3 Electronics original SPDES permit, but allowed by NYS DEC under a secret pilot program, with no public notice, no hearings, no public participation, and worst of all,  NO ENVIRONMENTAL REVIEW under SEQRA(*)". 

(* As far as we can tell. DEC has not yet answered all of our requests for records on this matter.)

This operator is the continuous progeny of IBM, which has left a toxic legacy here, dumping of massive amounts of dangerous chemicals in the ground and groundwater, due to neglect, incompetence, operator error, mechanical failure, and intentional illegal dumping.

THE ISSUE:

Since April, 2011, i3 Electronics in Endicott has been processing 80,000 gallons per day of highly toxic landfill leachate at their treatment facility, and dumping the effluent into the Susquehanna River. This activity was not permitted as part of their original SPDES permit, but was allowed under a secret "Pilot Program". Some of the leachate is highly concentrate "Reverse Osmosis Concentrate" trucked in from 2 hours away from Seneca Meadows, the largest landfill in NY, which takes municipal and industrial waste from 5 states, including NYC.

Concerned Citizens of Endicott / NY Friends of Clean Air and Water have serious concerns about this activity and its impact to the river and Endicott's drinking water. This operator (the progeny of IBM) has a LONG HISTORY of toxic chemical spills due to neglect, equipment failure, and intentional dumping. EIT defaulted on their promise to retain jobs in return for $30M in tax breaks, and over 10 years laid off most of their workforce. They defaulted on their creditors and declared bankruptcy in 2014. There was a spill of at least 17,000 gallons of raw leachate into the storm sewers in Feb 2014 when a valve on a rusty tank broke.

Won't the DEC protect us?

DEC tells us they do not have the staff to investigate every permitted SPDES site. They do not do plant inspections of the physical integrity of the tanks and plumbing. They almost never fine operators for violations. DEC never does independent testing of the effluent; they almost always approve permits (as long as they are filled out right). All chemical analyses is "Self-Reporting"—the Honor System!

What is happening now?

On June 29th, DEC published the availability of a draft SPDES permit renewal with a modification to make the treatment and dumping of the highly toxic leachate "official" and permitted. The original comment period of 30 days has now been extended until late September.

GREAT PRESS!

What can I do?

Please look at the materials we have collected here: TinyURL.com/StopTheStinkTrucks . This includes the permit application, the SEQRA docs released so far, and the draft permit.

We will be holding upcoming educational events, and comment writing workshops. Please keep in touch in one of these ways:

How to make a comment to the DEC:
  • CONTACT: Teresa Diehsner: (518)402-9167 DEPPermitting@dec.ny.gov
    REFER: SPDES NY#0003808 / i3 Endicott
    "Stop the Stink Trucks! No commercial waste dumping in the Village of Endicott!"

  • Please use the CCoE's list of 16 Demands to guide your comments:
More info:

Contact CCoE:

William Huston: WilliamAHuston@gmail.com
Mark Bacon: Mark's Cafe, 1412 North St., Endicott NY, 13760. 607-785-7565

Concerned Citizens of Endicott, in partnership with:





--
--
May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

Thursday, July 21, 2016

NYSDEC to extend the i3 draft Permit Public Comment Period and Hold Hearings

Thanks Rachel! Yes this seems like a great first step. I talked to Mark Bacon and he was not so happy. He brought me back to earth. Here is our joint statement on behalf of CCoE:

Mark Bacon and Bill Huston,  steering committee for Concerned Citizens of Endicott make this statement:

"These trucks have been dumping 80,000 gallons of poison per day in Endicott since 2011. This waste was never allowed under i3 Electronics original SPDES permit, but allowed by NYS DEC under a secret pilot program, with no public notice, no hearings, no public participation, and worst off all,    NO ENVIRONMENTAL REVIEW under SEQRA(*). Still the trucks continue. This operator is the continuous progeny of IBM, which has left a toxic legacy here, dumping of massive amounts of dangerous chemicals in the ground and groundwater, due to neglect, incompetence, operator error, mechanical failure, and intentional illegal dumping. We will be happy when these trucks stop bringing poisons into a Village which is already a TCE contaminate Superfund site."

(* As far as we can tell so far. DEC has not yet answered all of our requests for records on this matter.)

-- Bill Huston, Mark Bacon; Concerned Citizens of Endicott


On Thursday, July 21, 2016, Rachel Treichler <rachel@ecobooks.com> wrote:
> Good news!
>
> From: tim.digiulio@dec.ny.gov
> CC: reginald.parker@dec.ny.gov, sandra.lizlovs@dec.ny.gov
> Sent: 7/21/2016 3:02:49 P.M. Eastern Daylight Time
> Subj: NYSDEC to extend the i3 draft Permit Public Comment Period and will hold a Hearing
>  
>
> All,
>
> Due to the enhanced public interest in regards to the i3 draft Permit, NYSDEC will hold a Public Information Session and Legislative Hearing along with extending the public comment period.  The Department is working on scheduling a date and location but anticipates the Public Information Session and Hearing will be held in mid-September and the public comment period will be extended until the end part of September.  Please share this news with others who may not be on this distribution.  Once the details are finalized, a formal announcement will be made.
>
> Timothy DiGiulio, P.E.
>
> Regional Water Engineer
>
> New York State Department of Environmental Conservation
>
> Region 7
>
> 615 Erie Blvd. West, Syracuse, NY  13219
>
> P: (315) 426-7500 | tim.digiulio@dec.ny.gov
>
> www.dec.ny.gov           
>
>  
>
>  
>
>  
>
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--
--
May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

Tuesday, July 19, 2016

Some Great press and a Call to Action

This is really one of the best pieces I have ever seen on an environmental issue. There is no industry spin, they got all the essential facts in there, and everything is correct! Vince Briga and Camille DeLongis with Time Warner News deserve great credit for this!

The only think I wished for was the Link to the Documents Collection: TinyURL.com/StopTheStinkTrucks  ... but that is a small detail considering how much they got right

2. Conference Call Summary

We had a great conference call. Around 15 people attended.
Here is my summary of the main presentations.

1) Intro to the issue / Site History by Bill Huston


2) LAW: Environmental attorney Rachel Treichler explains the NY State SPDES program under the federal Clean Water Act, the NY SEQRA law, and basic ways to fight the permit, and some strange things she observed about this one.

3) CHEMISTRY: Dr. Ron Bishop frightens us all with the realities of Reverse Osmosis Concentrate chemistry, the volumes involved, and some discoveries he made which could stall the permit application in its tracks.

Rachel and Ron gave us some very important ways to stop or slow this permit, so be sure to check out what they had to say.
Audio will be posted soon...

3. REMINDER! Just 2 weeks left to comment to DEC!

URGENT!! This takes just 5 minutes.... Please write to the DEC and ask for the following things.

1) 90 days extension
2) Public Hearings
3) and Info Sessions

Teresa Diehsner
NYSDEC Headquarters
625 Broadway
Albany, NY 12233
(518)402-9167
DEPPermitting@dec.ny.gov
Refer: i3 Electronics Endicott SPDES permit NY#0003808.
If so moved, please tell the DEC that you support the Concerned Citizens of Endicott's 16 demands, including a site tour, all documents easily accessible to the general public, both online and in local libraries, and a site tour.

http://williamahuston.blogspot.com/2016/07/expedited-foil-request-90-days-comment.html

4. PLEASE CONTACT DONNA LUPARDO!

If you have 5 additional minutes to spare, PLEASE CONTACT Assemblywoman Donna Lupardo for SUBSTANTIVE help on this issue, especially if you live in her distruct (123rd Assembly District).

We want THREE THINGS from Donna:

a) a letter to DEC asking for 90 days extension, public hearings, and info sessions, (she has told us she agrees to these, but so far, NO LETTER. We don't have much time left!) Show us that you are on our side, Donna.

b) to meet with Concerned Citizens of Endicott and hear our concerns. (She knows where to find us). and
 
c) INFORM her constituents about the issue via social media and her emailed newsletter and give them instructions about how to make a comment to DEC.

Thanks
Donna Lupardo office phone: 607-723-9047
email: LupardoD@nyassembly.gov

Again--- we have LESS THAN 2 weeks left.
Please help share this on social media
(check NY Friends of Clean Air and Water, and also WBESC on Facebook)
and on relevant NY and downstream (PA, VA, MD) environmental lists

This graphic lists all of the downstream communities:



5. Visit STOP THE STINK TRUCKS World Headquarters!

If you want more information, stop by Mark's Coffee Shop, 1412 North St. in Endicott, 13760 any day, M-F 6am till noon.


​Mark Bacon, at Stop the Stink Trucks World HQ: 1412 North St., Endicott:
(607) 785-7565

Thanks for your interest in this issue.

BH

--
--
May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

Thursday, July 14, 2016

Stop the Stink Trucks! (Endicott)


Document collection is here: Stop the Stink Trucks
or Stop the Stink Trucks
or http://changetheframe.com/~bhuston/i3PermitApp.html
or http://tinyURL.com/StopTheStinkTrucks

All these go to exactly the same place. 
-- Bill Huston


(This page exists only to seed Google Search so that if you search for "Stop the Stink Trucks" it should take you here or there).

Wednesday, July 13, 2016

Notes from "Stop the Stink Trucks" call tonight

Also being posted to my blog:

Call notes. Please send corrections or additions to WilliamAHuston@gmail.com.
These notes are just for the presentations and not the full Q+A.

I will post audio shortly.

MANY THANKS to Rachel, Ron, and everyone for participating!

On the call:
  • Bill Huston
  • Rachel Treichler
  • Joan McKiernan
  • Chris Burger
  • Ron Bishop
  • Fred Sinclair CCAC
  • Jim Little
  • Scott Lauffer
  • James Betley
  • Betsy Norton
  • Gerry Wiley
  • Ron Bishop
  • Gudrun Scott
  • ... maybe a couple of others....?
Bill Huston's intro comments--

Contamination History--
  • Everyone knows Love Canal... but how many people realize Endicott is another Superfund site?
  • IBM corp got it's start in Endicott in 1911
  • History of contamination due neglect, accidents, and intentional dumping
  • In 1979 IBM Endicott reported a spill 4,100 gallons of TCE (methyl chloroform) a commonly used VOC solvent used in electronics manufacturing. 
  • A report prepared by IBM indicated that the plume was larger than expected and contained other industrial solvents. 
  • All of these VOCs and industrial solvents seeped into the groundwater.
  • Dozens of homes were demolished in downtown Endicott and are now a giant parking lot.
  • Since the discovery of the spill groundwater remediation and monitoring has been in effect and continuous to this day. 
  • Many homes, including the one where I live, have sub-slab ventilation systems installed.
  • In 2002 IBM found that the VOCs had in fact moved into the air in buildings on and around the spill site and in 2004 Endicott was classified as a class-2 Superfund site. -- "significant threat to public health and/or the environment and requiring action"
EIT

  • In 2002, IBM transferred ownership to the buildings and assets to Endicott Interconnect, Inc. / Huron Campus, which is owned by a pair of local wealthy families (Maines -- food distribution, Matthews-- auto dealership)
  • EIT promised to retain jobs, in return for $30M in tax deferments
  • EIT failed to retain these jobs, and in fact had massive layoffs,
  • Declared Bankruptcy July 2013 -- > became i3 Electronics
The waste treatment plant

  • IBM built a waste treatment plant in the 1970s(??) to treat and dispose of their process wastes created during manufacturing.
  • As manufacturing dwindled, the facility processed less wastes.
  • The site has 2 state-administered Clean Water Act permits, in NY called SPDES
  • We have heard reports from people that work there, the facility needs to process a minimum volume to keep the facility running.
  • Managers at EIT hatched a plan to turn the waste treatment facility into a commercial operation to handle imported industrial wastes.
  • In April 2011 they began a Pilot program under DEC approval under their existing SPDES permit to treat landfill leachate.
  • As far as we have been able to determine, this was done in secret, there was no public notice, no public hearings, and no environmental review under SEQRA!
  • In Feb 2013, 2 local citizens with WBESC saw a massive cleanup operation going on. After some investigation, they discovered a valve on a rusty tank broke and dumped the entire contents of raw unprocessed leachate into the storm drains, which dump directly into the Susquehanna River.
  • They made a FOIL to DEC, and confirmed the Pilot program for leachate processing.
WBESC

  • WBESC had it's first meeting on this 2-26-14 with DEC officials. The said the permit was up for renewal
  • Second meeting 5-3-16 to announce the permit was nearly ready.
  • Videos of these are online.
  • DEC printed a public notice of the availability of the permit on Friday July 1. "News Dump Day"
  • DEC DOES NOT provide key documents relating to this permit online, and requires that you FOIL them.
  • I have posted these docs on my website, but have not received all the docs requested.  
Status of the permit

  1. DEC says it does not have the regulatory authority to stop i3 Electronics from turning Endicott into a commerical waste dump.
  2. DEC never denies a permit (if it seems to be filled out correctly).
  3. DEC never performs safety inspections to check the integrity of the tanks or other plant facilities -- which have already leaked 17,000 gal of raw leachate in Feb 2013!
  4. DEC almost never assesses fines for non-compliance.
  5. DEC says there are "no limits" to how much effluent i3 Electronics can dump into the Susquehanna River, as long as it meets "Clean Water Standards" -- BUT NEVER CHECKS!
  6. DEC never performs independent testing of the influent or effluent
  7. ALL reporting is "self-reporting".... It's the HONOR SYSTEM!
  8. DEC does not have staff to check all permitted sites.
  9. DEC says a public hearing is "highly unusual"



Bill's Document Collection is here: TinyURL.com/StopTheStinkTrucks

Rachel Treichler:

  • CWA -> state administered permit SPDES
  • NY SEQRA --> permit requires environment review
  • GOAL: get the state to examine the environmental impact
  • So far -- DEC has not given this much attention
  • The don't have staff
  • DEC  @ May 3 meeting: "To get DEC to take action, there must be a lot of concern"
  • 60-70 people at May 3 meeting => GOOD! Public hearing is possible
  • Rachel introduces Ron Bishop, early activist in Fracking fight going back to meeting in Bath in 2008.
  • Ron in 2008: "We're all going to have to learn about fracking"
  • We have to do the same thing with these wastewater treatment systems
  • NOT just in Endicott, although RO Concentrate is concerning
  • Other NY landfills taking drilling waste (Hyland, Chemung)
  • Issuance of a permit or renewal triggers SEQRA
  • What is the impact on the Susquehanna River
  • Region-7-- Environment notice bulletin, June 29, proposed renewal and modification (extended under SAPA)
  • Many SPDES permits are issued for 5 years, then must be renewed.
  • SAPA says, if applicant files timely renewal, and DEC fails to act, the original permit is deemed continued. --> scandal
  • Indian Point Nuke plant -> permit extended for 10 years
  • DEC issued a "negative declaration" under SEQRA. This is an "Unlisted Action", no significant environemtal impacts.
  • SEQRA: Type-1 => full review, Unlisted => may require review, Type-2 => no review
  • "Withdrawing Groundwater in excess of 2M gallons per day" may be criteria for type-1
  • Treatment facility has capacity for 3M gpd. http://www.srbc.net/newsroom/NewsRelease.aspx?NewsReleaseID=81
  • If we can demonstrate will have environmental impact -->  may get EIS
  • DEC decided "no impact" with little support using a SEQRA short form
  • DEC filled out the form, which it looks like the Applicant should have!!
  • Rachel has questions about SEQR assessment form.
    • 3: Total acerage: Not applicable. Why?
    • 4: Adjacent Land Uses: Not applicable. Why?
      • What are the uses? Is there parkland?
    • Description: Accurate?
    • Impact assessment? Lots of questions.
    • 11 questions: Every questions answer is "no" or "small impact".
    • This is not a genuine assessment.
    • WE MUST MAKE a more accurate assessment
    • Determination of Significance.  "No significance"
    • Should be filled out by the applicant. This is filled out by DEC! Not right.
  • GOAL: turn around the negative declaration
  • Having a hearing is a possibility (DEC in May)
  • If Assemblywoman Lupardo is supporting us, good sign.
  • Seneca Lake example:
    • Negative Declaration was expected to sail through
    • 900 people came to hearing.
    • Then issues conference
    • Years of delay
  • Must keep organizing! Keep showing actual impacts.
  • Priority Ranking System: "Environmental Benefit Strategy"
    • They pick certain permits most in need of review.
    • Does not say ranking on the form.
    • However-- DEC website has list.
    • i3 ranking is "up there". Reasons=> Look at them. Accurate or Not? (2015 list)
    • "Any interested party may provide at any time substantive comments requesting a change in a permit's rank based on the ground newly discovered material info exists, that a material change in environmental conditions have occurred, or that relevent tech or applicable regs have changed the conditions of the existing permit".
Ron Bishop:

  • Last point Rachel made is critical. "Substantive change"
  • Very large change!!  6.8x increase in leachate production in one year!
  • Endicott is the preferred disposers for the SMI (not new)
  • crunching data
  • total raw leachate 2014 = 6M gallons  2015 = 40 M gallons!  much is coming to endicott
  • 2014: 5M gal to Endicott + 133k of RO Concentrate.
  • 2015: 1M gal raw leachate + 2M RO Concentrate 15x increase!
  • "Mt Trashmore" dramatic increase in productions
  • This was NOT how the permit was set up. It was set up as "gallons of leachate"
    up to 30k gal .... Now up to 2M gal of 10x Concentrated. 
  • Chemistry of how to treat
  • Inorganic chemicals / Heavy metals + Salts
    • Precipitate them out, starting with Lime (carbonates)
    • Sulfur (Sulfides)
    • Sent to treatment plant in Canada to reclaim metals
    • Other salts -- don't precp out well.  Diluting soluable salts with other stuff
  • Only effluent data from i3 was 2013/2014.
  • This was prior to massive scaleup of RO Concentrate
  • Tough to find out from DEC, because this is "proprietary info"
  • Other stuff is biological material
    • Use a digestor for this, chlorine or other biocide to kill it.
    • This increases biocides going into the river
Additional NOTES:
  • SRBC! water withdrawal?  Bill checks--
    • IBM Corporation, Endicott Facility, Village of Endicott, Broome County, N.Y., to modify approval to increase total groundwater system withdrawal by an additional 499,000 gpd for a total of 1.509 million gpd (30-day average) (Docket No. 20090329). 
    • Other facts-- very strange.
    • SRBC Water Resource Portal lists 12 wells. http://gis.srbc.net/wrp/
    • All say Facility IBM Corp-Endicott / "Approval Number" 20090329
    • All sites are at same location??? Approx 42.09785, -76.04916
    • All sites have 0 Mgal/d avg, 0 Mgal/d peak. 
      1. EN185 0/0
      2. EN160 0/0
      3. EN154 (decommissioned 2011)
      4. EN133 0/0
      5. EN120 0/0
      6. EN107 (decommissioned 2011)
      7. EN276 0/0
      8. EN253 (decommissioned 2011)
      9. EN222 0/0
      10. EN218 0/0
      11. EN195 0/0
      12. EN194 0/0
    • This DOES NOT JIVE with other info: http://www.srbc.net/programs/docs/Projects%20Scheduled%20for%20Action%20at%2003-12-09.PDF
  • Benefit Program-- 2015 ranking-- reasons? 
    REVIEW per Rachel
    http://www.dec.ny.gov/docs/water_pdf/ebps2015.pdf
  • "zombie permits" paper mentioned on the call is here: https://web.archive.org/web/20150913175531/http://digitalcommons.pace.edu/cgi/viewcontent.cgi?article=1134&context=pelr
  • Gudrun writes:

    I looked up the Code of Rules and Regulations of the State of NY  6RR-NY 617.5  were there are many examples of what constitutes a Type II action which is an action that calls for a negative declaration and no further environmental assessments no leader to conduct the environmental issues.
    Here is the lengthy list of actions that are Type II and these are the actions that are declared to not require an environmental impact declaration evaluation and the label will stick to the action:

    https://govt.westlaw.com/nycrr/Document/I4ec3a767cd1711dda432a117e6e0f345?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=%28sc.Default%29
    Read the various conditions that qualify for Type II  and there are over 30 different briefly described and here is the case of permit renewal :

    (26) license, lease and permit renewals, or transfers of ownership thereof, where there will be no material change in permit conditions or the scope of permitted activities;
    In the Endicott case there has been material change in the permit and also a change in scope all pointed out by Ron Bishop and so the situation is NOT Type II and that means not a negative environmental declaration. 

    I used the same law 6RR-NY 617.5  sentence (26) in the Hyland landfill case because they are using a new material (frack waste) and DEC allowed the increase of 49% more daily wastes in 2016-- DEC also warned that this was another no environmental impct case too.
    I found the email of Teresa...http://www.dec.ny.gov/enb/20160629_reg7.html
    Teresa Diehsner
    NYSDEC Headquarters
    625 Broadway
    Albany, NY 12233
    (518)402-9167
    DEPPermitting@dec.ny.gov



--
--
May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

emerg. conf. call tonight: Landfill Leachate Dumping in Endicott

Emergency Conference call tonight at 7pm concerning i3 Electronics SPDES permit modification/renewal which seeks to legitimize turning Endicott into a commercial waste dumping portal into the Susquehanna River, including presently 80,000 gallons per day of landfill leachate, includind super toxic reverse osmosis concentrate from Seneca Meadows.

This program began as a SECRET pilot program in 2011 with NO SEQR review!

We have an Emergency Conference Call coming up on wed, (tonight) with Rachel Treichler, esq., and Professor of Chemistry from SUNY Oneonta Dr. Ron Bishop.

The call will be:
Wednesday July 13, 7pm.,
Dial-in Number: (712) 432-0075
PIN: 129056

Please help get the word out!

Document collection, including application, draft permit, and links to our 6min viral video "Who put the stink in my drink?"
and blog posts explaining the issue:

http://TinyURL.com/StopTheStinkTrucks

If you can, please contact DEC by phone or email and ask for 90 days comment period. Also if you can, agree to the CCoE's 16 Demands, which should also include a demand for an EIS under SEQRA:

Refer: SPDES NY#0003808

Teresa Diehsner
NYSDEC Headquarters
625 Broadway
Albany, NY 12233
(518)402-9167
DEPPermitting@dec.ny.gov

Concerned Citizens of Endicott 16 demands:

http://williamahuston.blogspot.com/2016/07/expedited-foil-request-90-days-comment.html

--
--
May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

Don't forget to sign the
Pledge to Resist
the Constitution Pipeline:

Tuesday, July 12, 2016

David Cobb!! Thu (Endicott) + EMERG. CALL Wed: Stop the Stink Trucks (tomorrow)!

There are TWO important events listed below:

1: "Stop the Stink Trucks" Emergency Conference call Wed 7pm (tomorrow)
2: Move to Amend's David Cobb in Endicott Thu evening 7pm




Event #1: You may know that since 2011, 80,000 of highly toxic landfill leachate are being trucked into Endicott each day, minimally processed, then dumped into the Susquehanna River. We are now 1/2 way through a 30 day comment periods. This program was done IN SECRET by the DEC, and now this will soon be legalized, unless we can stop it.

We have an Emergency Conference Call coming up on Wednesday, (tomorrow) with Rachel Treichler, esq., and Professor of Chemistry from SUNY Oneonta Dr. Ron Bishop. The call will be: Wednesday July 13, 7pm., Dial-in Number: (712) 432-0075, PIN: 129056 Please help get the word out!

The Concerned Citizens of Endicott have 15 Demands.
FB event:  https://facebook.com/events/1062010573882017

Document collection, including the Application, SEQR negative declaration, draft permit, and public notice here:
TinyURL.com/StopTheStinkTrucks




EVENT #2

Please come hear former Green Party Candidate for President David Cobb Thursday Night July 14 at 7pm at Mark's Cafe, 1412 North St., Endicott!! Free event (outdoors) unless it rains.

https://www.facebook.com/events/1556763254629709/


He's a member of the National Leadership Team  for the Move to Amend organization, which was formed in response to the Citizens United case.

The issues are:
  • Are corporations people? Protected by Constitutional Rights?
  • Is money the same thing as speech?
  • How does this relate to elections?
  • Should wealthy corporations be allowed to spend unlimited amounts of money to influence elections?
David will likely connect this to fracking, the IBM chemical spill, and now leachate dumping. Please come if you can! (free)

David will be speaking on WNBF with Bob Joseph, 1290 AM
at 9:45 Thursday Morning.

BH

Thanks,
Bill Huston & Mark Bacon
Steering Committee, Concerned Cittizens of Endicott


--
--
May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

Thursday, July 7, 2016

My comments on PHMSA docket (NPRM for gas pipeline safety regs)

Sissonville composite showing aerial photo superimposed by diagram from the NTSB Pipeline Accident Report, with the predicted PIR circle (red) and the actual major impact area (yellow). Minor impacts such as melted siding was observed hundreds of feet beyond the yellow area.

Here are my comments on PHMSA's NPRM for gas pipeline safety rules. 
This includes ~3 years of work trying to calibrate the "Potential Impact Radius" (PIR) formula against real world data.

Here is a link to my comments on the docket:
https://www.regulations.gov/document?D=PHMSA-2011-0023-0411


Complete docket: https://www.regulations.gov/docketBrowser?rpp=25&so=DESC&sb=commentDueDate&po=0&dct=PS&D=PHMSA-2011-0023

I ran out of time, so it's not as well formatted as I would like. But at least something is now out there for review. There are a few details omitted in the interest of time and brevity. 

A web formatted version of the my primary comments on the NPRM are here:  http://williamahuston.blogspot.com/2016/06/bhs-preliminary-comments-on-phmsa.html

I will have a web-formatted version of my "Calibrating the PIR formula" soon.

Feel free to share this with other people who are interested in Natural Gas Pipeline Safety.

Constructive criticism appreciated.

MANY THANKS to those who supported my research, especially the month I spent working on the Salem incident.


Thanks,
BH


--
--
May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)


EXPEDITED FOIL Request + 90 days comment re: 7-0346-32/07 i3 Electronics Inc SPDES NY0003808

Hi Sandra, Tim, Reginald, Teresa,

FYI -- I have submitted FOIL Request :: W009352-070616

For the following documents:

In the public notice for the i3 Electronics SPDES permit NY#0003808 renewal, Application ID: 7-0346-00032/00007, I found this: QUOTE: State Environmental Quality Review (SEQR) Determination: Project is an Unlisted Action and will not have a significant impact on the environment. A Negative Declaration is on file. A coordinated review was not performed. ENDQUOTE I would like a copy of the SEQR "Negative Declaration" and all supporting documents. I would like CLEAR original documents, with searchable text. (not bad, unreadable scans) Thanks

The response I received says this:
"You may expect the Department's response to your request no later than 8/4/2016"

However, this is PAST the close of the comment period for NY3808 SPDES permit.

Can you please treat this request with expedited processing?

This information is a critical component to the package of documents which should have been provide to us LOCALLY for review. We should not have to drive to Albany as your public notice states. These data are critical for my comments on the docket and to evaluate whether SAPA and SEQR procedures were followed.

Additionally, I am asking for an immediate extension of the public comment period to 90 days so that our team can have adequate time to review this material.

My Assemblywoman Donna Lupardo joins us in this request for 90 days, as well as a request for additional public informational sessions, and public hearings in Endicott, and in downstream communities.

On behalf of Concerned Citizens of Endicott, and NY Friends of Clean Air and Water, I am making the additional PRELIMINARY commants/demands:
  1. 90 day comment period
  2. Multiple informational sessions in Endicott and downstream communities of Owego and Waverly, with personnel from i3 there (Pelto / Speranza) to answer questions
  3. Multiple public hearings in Endicott and downstream communities (Owego/Waverly) with 30 days advance notice, and a court stenographer present, were people can give oral testimony.
  4. FULL REVIEW of environmental impacts as per SEQRA (Type-1 Action => EIS)
  5. Copies of application, SEQR Negative Declaration, draft permit, and other relevant documents in public libraries in Endicott and in downstream communities (Owego, Waverly) available for review THROUGHOUT the duration of the 90 day comment period. (This may require a restart)
  6. Site tour for up to 10 of us, with ability to videorecord and publish.
  7. Stipulation: Local site-generated wastes ONLY-- no commercial, for-profit waste dumping operation in Endicott!
  8. i3 Electronics must post a $5M bond for cleanup costs from potential spills.
  9. DEC must perform a physical inspection of the plant by an independent engineer to assess the integrity of the tanks, piping and other equipment, and i3 must make repairs prior to the issuance of the permit should non-compliance be found.
  10. DEC must establish a protocol for doing CONTINUOUS MONITORING of the effluent and allow the public easy access to this data.
  11. DEC must establish a protocol for frequent and random site inspections, to check for proper operation, and operator qualifications.
  12. DEC must establish a protocol for establishing the qualifications of plant operators.
  13. DEC must establish a protocol for FINES for non-compliance with safety regulations or provisions of the Clean Water Act, including spills, and shut down the plant should another spill happen until the integrity of the equipment has been independently verified. (This site/operator has a LONG HISTORY of contamination due to intentional dumping, neglect, and incompetence)
  14. i3 Electronics must FOLLOW THE LAW with regards to notification of DEC and the community in the event of spills or equipment failures which endanger the public.
  15. DEC must perform an Ambient Air Test at 5 locations within 1/2 mile of the facility.
  16. Lastly, we want a member of our team to be able to obtain a grab sample of the effluent on an unannounced, random date/time for independent lab testing PRIOR to the close of the comment period.
Again, these are only my PRELIMINARY comments. Additional technical comments will be forthcoming when we are able to obtain all of the documents, and have adequate time to review.

Best Regards,
BH




--
--
May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)