An open letter to the Louisville Metro Government

Admin note:  I received word shortly after sending this letter that one of the two methane plants has been taken off the table.  While this is certainly progress the objections I raise below still apply to the remaining plant and as of this time have not been addressed by the city or the developers.

 

 

Mayor Fischer, Members of City Council,

I’m writing to you to express my concerns regarding the two methane plants planned for the West End.  Before I get to that though I’d like to tell you a little bit about myself.  I originally hail from Vermont but moved back and forth across the country a couple of times as I pursued my dreams and ambitions.  I come to you from Louisiana following six years of service in the Army as an Explosive Ordnance Disposal (EOD) Technician including a combat deployment to Afghanistan in support of 4th Brigade, 10th Mountain Division.  My wife Meghan and I fell in love with the city when we were presented with the possibility of being stationed at Ft. Knox and when I decided to leave Active Duty service a three day visit to Louisville sealed the deal and we haven’t looked back since.  Meghan and I originally moved to Portland but now reside in Chickasaw on Westchester Ave where we own our first home.  Following my service in the Army I briefly worked at Orica’s ANFO plant in Indiana and I worked as a civilian Unexploded Ordnance contractor.  My military training not only covered explosive hazards but also a wide variety of hazardous materials and I’ve also obtained a 40 hour HAZWOPER certification.  I consider myself very pro-business and pro-jobs.

Now onto the heart of the matter:  As much as I’m for development and job creation in general (and especially in the West End), I can’t help but look at both the plans for the methane plants and the secrecy and underhanded dealings surrounding them without finding myself gravely concerned for the physical safety of these communities and disturbed and disappointed at my city government’s actions.

Within the EOD community there is a central tenet that we hold which has been absolutely essential to our mission of protecting human life: “always presume the worst case scenario until you have positive confirmation otherwise.”  In practice what that means is that if nothing else we always operate under the assumption that any positive action we take will result in a high-order detonation (and/or whatever other ill effects might result from a failed procedure) and accordingly we take any and all appropriate actions to mitigate possible harm to human life or damage to property.  If people are present we have them evacuated, if property or infrastructure is threatened we build protective works, etc.  We most certainly would never, ever put a potentially hazardous item in a position where it would threaten the public.

After examining both sites for myself, it’s plain to my eye that these plants are to be located so as to put occupied homes within their hazardous blast/fragmentation radii.  I am also unable to identify any form of protective works in the public plans for the plants which would mitigate blast or fragmentation effects in the event of an explosion and/or contain material in the event of a spill (mind you each individual tank has a capacity of roughly 1.5 million gallons).  I believe that these plants are safe if they are operated and maintained 100% perfectly but experience tells me that perfection is an unrealistic standard in any process where humans are involved.  The STAR Energy FAQ page is correct to point out that methane ignites under a very narrow range of conditions (5-15% concentration) yet the company then neglects to mention that anaerobic digestion also yields hydrogen gas (anyone familiar with the Hindenburg?) which is flammable between 4% and 75% concentration under normal atmospheric conditions and yields sufficient explosive power to rupture a containment vessel (and expose methane and any other flammable materials in the mix to all of the atmospheric oxygen they could possibly want).  I can’t help but find myself skeptical that this omission is an accident.

It is without question that maintenance, cleaning, and changing from one input material to another in any anaerobic digester are all inherently dangerous operations with multiple means of creating an explosive atmosphere and thus conditions for fires, breaches, or explosions.  Can all of those tasks be performed safely?  Yes, absolutely but it is absolutely critical to understand that over time people will make mistakes, equipment and sensors will fail, and ultimately some procedures will not go as planned.  I’m certain that GE Water has engineered many failsafes into their digester technology but there is and will always be the potential for catastrophic failure no matter how well engineered these plants may be.

If these digesters were located in the middle of nowhere I wouldn’t be overly concerned due to the limited risk to human life however both of these plants are dangerously close to residential areas and major thoroughfares which see traffic at all hours of the day.  Both of these plants have an inherent capability to cause a mass casualty incident and I find this possibility completely unacceptable given the standard of perfection which must be maintained in order to ensure plant and ultimately neighborhood safety.  I feel that to locate these plants in populated areas is ultimately an expression of run-away hubris rather than certainty of a safe installation.

As a safety professional I find myself searching for explanations as to why no kind of environmental impact study would be required for these plants, if only to ensure the safety and welfare of people in the community.  A cursory investigation on my part has revealed that the anaerobic digestion process involves a number of hazardous and/or corrosive chemicals (including known carcinogens) such as chloroform and sodium hydroxide.  It seems grossly irresponsible to me to not even investigate the possible impacts of these plants on the people in their communities and I can only lay the blame for this at the feet of you, my city government.  Seed Capital KY and their associates have not done these studies because you have not required it of them.  We know this for a fact because they have told us as much at the Urban League meeting.  What is worse, I can only speculate that an environmental impact survey has not been ordered because the mayor and city council believe that it will return with answers which they do not wish to hear.  Regardless of the city’s motives, I am entitled to expect better from my leadership.

While the above is a short summary of my ‘life and limb’ concerns, I’m also troubled by a number of social and economic factors.  Anaerobic digestion has a spotty record when it comes to economic viability; it seems that if you’re a large dairy farm or some other entity which produces gross quantities of biomass on site, then they’re certainly a viable option.  However, given that these two digesters are not located on the same site as their input material, I believe that these plants will have a lot of difficulty breaking out of the red considering the best projections expect 15% returns.  I’m skeptical that they’ll even be carbon neutral given the amount of truck traffic that will be required to keep the plants operating.  If this were an entirely private venture setting up shop in the middle of nowhere I’d be perfectly happy to let organizations who are completely unvetted and untested in the realm of anaerobic digestion roll the dice and either succeed or fail.  Hell, I might even send them my resume.  However this isn’t a private venture.  There are millions of city and state tax dollars in play here and I’m more than a little dismayed that my city government is so eager to gamble public property and funds on a set of projects that are (to put it mildly) fiscal wobblers.  What are the city’s plans if these plants fail?  Who will be on the hook to tear down the rusting infrastructure and clean up the HAZMAT problem that’s been left in its wake?

Finally, I’d like to warn the mayor and city counsel that the secrecy, lack of consultation, and (from our perspective) apparent double-dealings that have surrounded this entire project have left myself and too many others in my community a very dangerous vacuum in which to speculate.  When I look at Seed Capital KY’s food port web page I find that nearly every statement made on the site has been contradicted by information to have come out at or since the Urban League meeting I feel I’ve been lied to.  When I read Brian Zoeller’s statements on behalf of Nature’s Methane I see someone who is profoundly out of touch with the actual concerns of the community.  When I take time off work to attend a public meeting and my elected leadership and representatives from Seed Capital KY and Nature’s Methane are nowhere to be seen I can only presume that the lot of you are afraid of having to answer tough questions.  The radio silence is deafening.  We can only view your opaqueness as duplicity because as we search for rational explanations for this behavior none of them are consistent with above-board dealings much less a city government which even gives a damn.  There is a perception of disrespect, condescension, and corruption and we are left with nothing with which to dispel those perceptions.  I don’t believe that you begin to appreciate the anger and resentment that’s brewing all across the West End at this time and I fear that it ultimately has the potential to undermine revitalization efforts from Portland to Virginia Ave.  Your time to stop what you’re doing, listen to the community, and show us the transparency, consideration, and basic human respect which we deserve is growing very, very short.  Please listen.

Sincerely,

John Sisino