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Finger Lakes LPG Storage Project

Finger Lakes LPG Storage Project. Schuyler County, New York. Project Overview. Crestwood wants to use existing underground salt caverns located at its US Salt complex (Reading, New York) for liquefied petroleum gas (LPG) storage salt caverns were created by US Salt for brine production

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Finger Lakes LPG Storage Project

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  1. Finger Lakes LPG Storage Project Schuyler County, New York

  2. Project Overview • Crestwood wants to use existing underground salt caverns located at its US Salt complex (Reading, New York) for liquefied petroleum gas (LPG) storage • salt caverns were created by US Salt for brine production • Crestwood wants to store 2.1 million barrels of LPG (1.5 million barrels of propane and 600,000 barrels of butane) • Combination of close proximity to existing pipeline infrastructure (TEPPCO pipeline) and existing caverns filled with brine makes the site ideal for LPG storage • project footprint is more environmentally friendly than constructing a new “greenfield” storage facility • the Watkins Glen brine field and US Salt’s operations cannot be relocated, (i.e., this is where we can help solve NY’s propane delivery problem) • Project does not involve: • storage of natural gas • fracking • caverns located under Seneca Lake US Salt has been mining salt along the shores of Seneca Lake since the 1890s. Inergy Midstream purchased US Salt in 2008, and purchased NYSEG’s natural gas storage facility located on US Salt’s property in 2011. InergyMidstream changed its name to Crestwood Midstream Partners after merging with another public-traded company in October 2013. References to Crestwood include its predecessors and subsidiaries. 2

  3. Overview of LPG Storage in New York 3

  4. Highly Regulated Activities with Strong Track Record • Storage (New York Department of Environmental Conservation) • Regulated US Salt’s salt mining operations for decades (including well / cavern geological data) • Decades of experience regulating LPG storage facilities in New York / Finger Lakes • Scrutinized every aspect of proposed Finger Lakes LPG storage caverns, and will require significant verification / testing before allowing Crestwood to store LPG in the caverns • Storage (Federal Energy Regulatory Commission) • Most experienced US regulator of gas storage facilities • Reviewed US Salt caverns for natural gas storage on three different occasions (1997, 2002, and 2014), and each time determined that the caverns were suitable for gas storage • FERC rejected / rebutted claims by EarthJustice / Gas Free Seneca and its experts that the caverns were not safe for storage when approving an expansion of Crestwood’s natural gas storage facility located at the US Salt complex (May 2014) • Relevant because caverns proposed for LPG storage are substantially similar to, and located in the same salt formation as, the caverns today used for natural gas storage (and caverns suitable for natural gas storage are customarily suitable for LPG storage) • Transportation • TEPPCO’s pipeline activities are highly regulated by the FERC and the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (“PHMSA”) • Norfolk Southern’s rail activities involving hazardous materials are highly regulated by the Department of Transportation’s Federal Railroad Administration, PHMSA and the National Transportation Safety Board • 99.9977% of all hazardous material rail shipments last year arrived at their destination without a release caused by rail incident • Over-the-highway transportation of LPG regulated by the Federal Motor Carrier Safety Administration, PHMSA and National Transportation Safety Board Proven industry track record of safe LPG storage and transportation throughout the Finger Lakes 4

  5. Local Natural Gas Storage Provides Context • 26 natural gas storage facilities located in New York (23 using depleted oil and gas reservoirs / 3 using salt caverns) • 24 FERC-regulated natural gas storage facilities in New York • Largest natural gas storage field (Woodhull Field) is located in Steuben County • Established track record of underground storage activities within the Finger Lakes / Southern Tier further demonstrates that gas storage activities can be done safely and in an environmentally-responsible manner • Local gas storage examples include: 5

  6. Beyond the Politics • A decision is long overdue • Permit application filed in Fall 2009, but still waiting for decision after 5 years despite: • Two public hearings in Fall 2011 • Numerous voluntary concessions made in 2012 to address public concerns • DEC Staff indicated its approval in 2012 and has had a permit ready for issuance since early 2013 • State Geologist approved storage project in March 2013 (required for DEC to issue underground storage permit) • Politics are trumping science and facts • Significant project benefits • Adds $25+ million to local tax base • Adds 50 construction jobs and 10+ good-paying permanent jobs • Protects more than 235,000 New York residential consumers against price volatility and ensures supplies are available locally • propane is the primary heating fuel in Schuyler and Yates Counties (with market share > 25%), and propane heats more than 15% of the homes in five other Upstate counties • on average, New York households paid 43% (or more than $410 per household) more last winter to get propane from farther away places, translating into $100+ million of higher delivery costs statewide that could have been avoided if more propane was stored locally and made available • Promotes clean-burning fuel and domestic energy independence • Don’t believe everything you hear • Supported by “home” county (Schuyler County Legislature passed resolution of support in June) • Supported by United Steel Workers – District 9 (after comprehensive safety review) • Supported by national and state propane gas associations and its members • Supported by dozens businesses throughout Upstate New York • Many opponents have not sought out, or do not otherwise have access to, the facts … which results in misinformation 6

  7. Concerns (Brine Ponds) • “Brine Will Spill Into / Contaminate Seneca Lake” • design and engineering standards of the brine ponds will exceed DEC standards required to permit “dams” • consistent with DEC’s “dam” permitting standards, a hazard risk analysis was performed • unanticipated failure of embankments would not jeopardize human life • unlikely combination of extreme rainfall and sustained wind of high velocity would not cause any pond to overflow • any settlement caused by seismic event would be negligible • safety and environmental protective features include, among others, • a double liner with leak detection system and monitoring • an engineered embankment to prevent breach of the pond • daily brine level monitoring • processes to automatically route brine to US Salt’s plant in certain circumstances • design life of pond embankments exceeds 100 years, and the pond liner’s life expectancy exceeds 20 years • reconfigured layout / location of the brine ponds renders it improbable that any released volumes could ever reach Seneca Lake • groundwater quality monitoring • Crestwood is in the process of updating / replacing US Salt’s brine pipelines, which further reduces the risk of leaks as brine is transported between ponds / storage caverns / US Salt’s plant • chlorides in Seneca Lake are down >15% since natural gas storage was introduced at US Salt and, according to 2012 report prepared by an expert from the Finger Lakes Institute (John D. Halfman), the land uses along the lake suggest “the primary water quality threat to the lake is nutrient loading from organic wastes and agriculture runoff” Extremely unlikely that any significant quantity of brine would ever reach Seneca Lake, let alone impact a 4.2-trillion gallon lake 7

  8. Concerns (Other) • “Geology Is Unsafe For LPG Storage” • History of LPG and natural gas storage in US Salt’s caverns without incident demonstrates the caverns are sound for storage. • same caverns used for LPG storage are today used for natural gas storage (35+ years) • Three FERC rulings on natural gas storage activities using US Salt caverns affirm they are safe for storage. • New York State Geologist endorsed the LPG storage project, citing the local salt formation’s “longstanding operational record as a gas storage facility without any geologic evidence of incompatibility for this intended purpose.” • Nearby LPG storage facilities in same salt formation are another reminder that the geology is sound. • Other third parties consultants that have reviewed the geology for other uses (including NYSEG’s proposed compressed air energy storage project in December 2011) have reached similar findings of suitability for storage. • “Proposed Facilities Will Ruin Our Views” • Neighbors and visitors will not be able to see LPG storage facilities from Seneca Lake. • Crestwood conducted a visual impact assessment in accordance with DEC policies. • At worst, the top of the East pond (or its embankment) might be viewable under certain scenarios. • would look like a country pond surrounded by native grasses • “Industrialization Will Ruin Tourism & Winery Industries” • LPG has been stored and transported in the Finger Lakes safely during the period in which the local tourism and winery industries have experienced substantial growth. • LPG is used by many local businesses, including wineries, and their employees (over 3,500 households in Schuyler County alone). • No empirical basis for claiming LPG storage activities will ruin local tourism or air quality. • new gas storage and transportation facilities brought online during period of substantial growth for agribusiness industry prove that’s not the case • environmental testing (e.g., noise) performed to demonstrate no adverse impact 8

  9. Understanding / Quantifying the Risks • Background • Crestwood, at the urging of Gas Free Seneca and local communities, hired a national expert (Quest Consultants) on hazards and risk analysis in the energy sector to perform a quantitative risk analysis (QRA) for the proposed LPG storage project • Quest’s QRA was procured in addition to the hazard risk analysis for the brine ponds, traffic analysis, and geological analysis separately prepared and submitted to the DEC • A retired health care executive (Dr. Rob Mackenzie) recently prepared and circulated a “High-Level QRA” concluding that (i) the likelihood of an LPG disaster of serious or extremely serious consequences within Schuyler County in the next 25 years is more than 40% and (ii) from the perspective of community safety based on his analysis, Crestwood’s project poses unacceptable risk • Crestwood provided Mackenzie’s report to Quest for review • According to Quest, the mix of qualitative and semi-quantitative data, combined with an undefined set of risk categories, makes Mackenzie’s assessment of risk “highly subjective and easily biased” • According to Quest, Mackenzie’s use of incomplete consequence scenarios, calculation of vague 25-year probability ‘scores’, a risk matrix with undefined categories, and a lack of basis for existing transportation and salt cavern storage risks makes his risk assessment “invalid for use in determining the project future” • According to Quest, Mackenzie “does not present a balanced approach to the actual risks posted to Schuyler County residents by the LPG storage project,” where the primary shortcomings include: • complete disregard for existing risk. Existing local risk (implicitly viewed as acceptable) includes LPG pipeline, LPG truck traffic, hazardous material railcar traffic, and cavern risks associated with the storage / movement of natural gas and brine • if Crestwood’s project only marginally affects existing risk, then it’s hard to argue the project is unacceptable due to risk • inappropriately bases all consequence evaluations on catastrophic risks (i.e., disregard of accident scenarios with little-to-no consequences is a misrepresentation of reality), and ignores events where mitigation measures may prevent or eliminate public impacts • does not properly account for the anticipated railcar and truck traffic attributed to the project. The probability estimates of railcar and truck accident scenarios are based on generalized data, rather than project-specific transportation estimates 9

  10. Crestwood in New York today • Significant local investment • Crestwood has invested more than $830 million in the State, about one third (or $278 million) of which has been made in Schuyler County (including approximately $163 million in US Salt), through December 31, 2013 • Growth opportunities like the Finger Lakes LPG storage project support continuous capital investments to modernize and upgrade US Salt’s operations (because salt production is not a growth business yet requires significant capital) • Significant contributor to state and local economies • Crestwood has more than 180 employees in New York, including more than 145 employees in Schuyler County • employs about 100 employees who are represented by the United Steel Workers at US Salt • Crestwood is one of Schuyler County’s largest, if not largest, taxpayers and non-public employers • Crestwood has helped make Reading’s household income the highest in Schuyler County • in the past two years (2012-2013), Crestwood has paid almost $190 million to New York vendors and paid more than $7.3 million in real property tax (including more than $850,000 of real property tax in Schuyler County) • project expected to add $25 million of tax base, translating into more than $650,000 of annual property tax revenue • helps to fund schools and public services, and helps to avoid the need for tax hikes for local businesses and residents • Significant experience with natural gas and LPG storage and related services • owns and operates four natural gas storage facilities in Tioga, Steuben and Schuyler Counties • owns and operates LPG storage facility in Steuben County • owns and operates a brine and salt company with 100+ years of operations next to Seneca Lake • one of the largest propane marketers in the U.S. (e.g., significant experience moving LPG by pipeline, rail and truck) • U.S. Senator Gillibrand helped Crestwood obtain a $500,000 grant from the United States Department of Energy for this LPG storage project (promotes clean energy) 10

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